pa99 Privacy Policy — Your Data, Protected

pa99 collects personal data from users through several channels: directly during registration and account management, automatically through your use of the platform, and from third-party partners where necessary to verify your identity or process payments. The categories of data we collect are described below.

1.1 Data You Provide Directly

When you register a pa99 account, use the pa99 Login page, contact our support team, or participate in promotions, you may provide the following information:

• Identity data: Full legal name, date of birth, gender (optional), and nationality
• Contact data: Email address and Bangladesh mobile phone number
• Authentication data: Username and encrypted password (passwords are never stored in plain text)
• Verification documents (KYC): Bangladesh National ID Card (NID), passport, birth certificate, and in some cases a utility bill or bank statement confirming your address
• Financial data: Mobile wallet number (bKash, Nagad, Rocket, Upay) or bank account details used for deposits and withdrawals, transaction history, and deposit/withdrawal amounts in Bangladeshi Taka (৳)
• Communications: Records of any support chat, email, or complaint you submit to pa99, including the content of those communications

1.2 Data Collected Automatically

When you access and use the pa99 platform, our systems automatically collect certain technical and behavioural data:

• Device and connection data: IP address, browser type and version, operating system, device model, and screen resolution
• Usage data: Pages visited, time spent on each page, game sessions started, wager amounts placed, features used, and navigation patterns
• Session data: Login timestamps, session duration, logout events, and pa99 Login history
• Geolocation data: Approximate location derived from your IP address (used to verify Bangladesh residency and detect access from restricted territories — pa99 does not access GPS-level location data)
• Cookie and tracking data: See Section 4 (Cookies & Tracking Technologies) for full details

1.3 Data from Third Parties

In limited circumstances, pa99 may receive personal data about you from third-party sources including:

• Payment processors (bKash, Nagad, Rocket, Upay, and bank partners) confir ming transaction status and your registered mobile number
• Identity verification services used during the KYC process to cross-check submitted documents
• Fraud detection and anti-money laundering screening services that flag high-risk account activity patterns
• Game studios (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Ezugi, and others) who may share anonymised session data for technical support and game integrity purposes

pa99 only requests data from third parties where there is a legitimate purpose directly related to your use of the platform. We do not purchase personal data lists from data brokers or marketing agencies.

pa99 processes your personal data only where there is a clear and lawful basis for doing so. The purposes for which we use your data, and the corresponding legal basis for each, are set out in the table below.

Purpose	Data Used	Legal Basis
Account registration and management	Identity, contact, authentication data	Performance of contract
Age and identity verification (KYC)	Identity data, verification documents	Legal obligation; responsible gaming compliance
Processing deposits and withdrawals	Financial data, mobile wallet details	Performance of contract
Fraud prevention and security monitoring	Device data, IP address, usage data, session data	Legitimate interests; legal obligation
Customer support and dispute resolution	Communications, account history	Performance of contract; legitimate interests
Bonus and promotional eligibility	Transaction history, usage data	Performance of contract
Platform analytics and improvement	Usage data, device data (anonymised)	Legitimate interests
Responsible gaming monitoring	Usage data, deposit history, session data	Legal obligation; user safety
Service communications (account notices)	Contact data	Performance of contract
Marketing communications (opt-in only)	Contact data, usage preferences	Consent (you may withdraw at any time)

pa99 does not use your personal data to build individual behavioural profiles for sale to advertisers, nor do we engage in automated decision-making that produces legal or similarly significant effects on your account without human review. Where automated systems flag an account for suspension, a member of the pa99 compliance team conducts a manual review before any action is taken.

pa99 does not sell your personal data. We share personal data with third parties only in the specific, limited circumstances described below, and only to the minimum extent necessary for the stated purpose.

3.1 Payment Processing Partners

To process your deposits and withdrawals in Bangladeshi Taka (৳), pa99 shares relevant financial and identity data with payment service providers including bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, and Islami Bank. These providers operate under their own privacy policies and are bound by Bangladesh financial regulations. pa99 shares only the data strictly required to complete your requested transaction.

3.2 Identity Verification Services

pa99 uses third-party KYC service providers to verify the authenticity of identity documents submitted during account verification. These providers receive only the documents and basic biographical data required for the verification task and are contractually prohibited from using that data for any other purpose.

3.3 Game Technology Providers

Game content on the pa99 platform is provided under licence from studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi. These providers may receive a unique anonymised player identifier and game session data for the purposes of game delivery, technical support, and game integrity monitoring. They do not receive your name, mobile number, payment details, or any other directly identifying information.

3.4 Legal and Regulatory Disclosure

pa99 may disclose personal data to government authorities, law enforcement agencies, or regulatory bodies where required to do so by applicable law, court order, or in response to a lawful request relating to fraud, money laundering, or other criminal investigations. In such cases, pa99 will disclose only the minimum data required by the legal obligation and will, where permitted, notify the affected user of the disclosure.

3.5 Business Transfers

In the event that pa99 undergoes a merger, acquisition, or sale of all or substantially all of its assets, 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 the applicable privacy terms via the email address registered to your pa99 account.

pa99 uses cookies and similar technologies (including local storage and session tokens) to operate the platform effectively, maintain your login session, prevent fraud, and understand how users interact with the site. Below is a breakdown of the cookie categories used on pa99.

Cookie Type	Purpose	Can Be Disabled?
Strictly Necessary	Maintain your login session via the pa99 Login page, remember your language preference, and prevent cross-site request forgery (CSRF) attacks. These are essential for the platform to function.	No — required for core functionality
Functional	Remember your game preferences, last-played game, display settings, and notification preferences so you do not have to re-enter them on each visit.	Yes — via browser settings
Analytics	Collect anonymised data on page visits, click patterns, and session duration to help pa99 identify areas for platform improvement. No personally identifying data is included in analytics reports.	Yes — via browser settings
Security / Fraud Prevention	Detect unusual login patterns, identify multiple accounts sharing the same device or IP address, and flag bot-like behaviour inconsistent with genuine human interaction.	No — required for account safety

pa99 does not use third-party advertising cookies, retargeting pixels, or social media tracking cookies. You may manage or delete cookies at any time through your browser's privacy settings. Please note that disabling functional cookies may affect your user experience on the platform — for example, your session may not persist between page loads. Deleting security cookies may trigger additional verification steps during your next pa99 Login.

pa99 retains personal data for defined periods that reflect the purpose of the data and the applicable legal requirements. The following retention schedule applies to the main data categories held by pa99:

• Account identity and contact data: Retained for the duration of your active account and for 5 years following account closure, to satisfy anti-money laundering and KYC record-keeping obligations.
• Financial transaction records: Retained for a minimum of 5 years from the date of each transaction, in line with standard financial compliance requirements applicable to Bangladesh-facing platforms.
• KYC verification documents: Retained for the duration of your account and for 5 years post-closure. Copies are stored in encrypted form and accessible only to the compliance team.
• Game session and wagering data: Retained for 3 years from the date of each session, after which it is aggregated and anonymised for statistical purposes.
• Support communications: Retained for 2 years from the date of the communication, or longer where the communication relates to an ongoing dispute or legal matter.
• Marketing preferences and consent records: Retained for the duration of your active account. Consent withdrawal records are retained for 3 years as evidence of compliance.
• Analytics and usage data (anonymised): Retained indefinitely in anonymised, aggregated form. This data cannot be used to identify individual users.

pa99's servers and data storage infrastructure are secured with access controls, encryption at rest, and regular security audits. Data is processed within secure environments and is not stored on unencrypted portable media.

pa99 implements a layered security architecture to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Our security programme includes the following measures:

• 256-bit SSL/TLS encryption on all data transmitted between your device and the pa99 platform, ensuring that data in transit cannot be intercepted or read by third parties.
• Encryption at rest for all sensitive personal data stored on pa99's servers, including identity documents, financial records, and authentication credentials.
• Password hashing using industry-standard one-way cryptographic algorithms. pa99 never stores your password in readable form. Even pa99 staff cannot retrieve your password — only a reset is possible via pa99 Login.
• Access controls that restrict access to personal data to only those pa99 employees and contractors with a legitimate need-to-know basis for their specific role.
• Regular security audits and vulnerability assessments conducted to identify and remediate potential weaknesses before they can be exploited.
• Fraud monitoring systems that operate continuously to detect unusual transaction patterns, multiple-account activity, and other behavioural indicators of security risk.
• Incident response procedures that are activated in the event of a confirmed or suspected data breach, including user notification where required.

While pa99 takes all reasonable and commercially practical steps to protect your data, no digital platform can guarantee absolute security. You also play a role in keeping your account secure: use a strong, unique password for pa99 Login, do not share your credentials with anyone, and notify us immediately if you suspect unauthorised access to your account at [email protected].

As a pa99 user, you have meaningful rights over your personal data. These rights are available to all registered members and can be exercised by contacting our support team at [email protected] with the subject line "Data Rights Request". We will acknowledge your request within 5 business days (Bangladesh Standard Time, UTC+6) and aim to resolve it within 30 calendar days.

7.1 Right of Access

You have the right to request a copy of the personal data pa99 holds about you, the purposes for which it is being processed, and the categories of third parties with whom it has been shared. We will provide this information in a clear, structured format.

7.2 Right to Rectification

If any personal data we hold about you is inaccurate or incomplete, you have the right to request correction. Minor updates (such as email address changes) can be made directly through your pa99 account settings. Changes to legally significant data (such as your full name or date of birth) may require supporting documentation.

7.3 Right to Erasure

You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (for consent-based processing), or where you object to processing and there is no overriding legitimate interest. Note that pa99 cannot delete data that we are legally required to retain — for example, financial transaction records subject to anti-money laundering obligations. In those cases, we will explain what can and cannot be deleted and why.

7.4 Right to Object to Marketing

You have the absolute right to object to the use of your data for marketing communications at any time. You can withdraw your marketing consent by emailing [email protected] or by updating your preferences in your account dashboard. Withdrawal of marketing consent does not affect your ability to use the pa99 platform or receive essential service communications (such as withdrawal confirmations or account security alerts).

7.5 Right to Data Portability

Where pa99 processes your data on the basis of consent or contract, you have the right to receive a copy of that data in a commonly used, machine-readable format (such as CSV or JSON) for the purpose of transferring it to another service. Submit a portability request to [email protected] with the subject line "Data Portability Request".

7.6 Right to Restrict Processing

In certain circumstances — for example, while a dispute about the accuracy of your data is being resolved — you may request that pa99 restrict the processing of your personal data to storage only. During a restriction period, we will not use your data for any other purpose without your consent.

pa99 reviews and updates this Privacy Policy periodically to reflect changes in our data practices, platform features, or applicable legal requirements. The "Last Updated" date at the top of this page indicates when the most recent revision was made. For material changes — those that significantly affect your rights or the way we use your data — pa99 will notify registered users by email at least 14 days before the change takes effect, giving you time to review the updated policy and, if you do not agree, to close your account and request data deletion before the new terms apply.

Continued use of the pa99 platform after the stated effective date of a policy update constitutes acceptance of the revised Privacy Policy. If you disagree with any change, please contact our support team before the effective date to discuss your options or to request account closure and data handling under the prior policy terms.

8.1 Children's Privacy

The pa99 platform is strictly for adults aged 18 and above. pa99 does not knowingly collect personal data from individuals under the age of 18. If we become aware that personal data has been collected from a person under 18, we will immediately close the associated account, delete the data, and handle any funds in accordance with applicable legal obligations. If you believe a person under 18 has registered a pa99 account, please notify us immediately at [email protected].

8.2 Links to Third-Party Sites

The pa99 platform may contain references to third-party payment providers or game studios. pa99 is not responsible for the privacy practices of those external parties. We encourage you to review the privacy policies of any third-party service you interact with — particularly your mobile wallet provider (bKash, Nagad, Rocket, or Upay) — to understand how they handle your data independently of pa99.

8.3 Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact the pa99 Privacy team using the details below. All correspondence should be submitted in English and include your registered username and the nature of your enquiry for efficient routing.