09bb Privacy Policy — How We Protect Your Data

1. Introduction

09bb ("the Platform", "we", "us", "our") is committed to respecting and protecting the privacy of every player who interacts with our online casino and sports betting services. This Privacy Policy sets out in clear, formal terms how we collect, use, store, share, and ultimately dispose of personal data relating to players based primarily in Bangladesh and any other jurisdiction from which the platform is accessed.

This policy applies to all personal data processed through the 09bb website at https://09bb.io, through any associated mobile browser interface, and through any direct communication channel such as email or live chat support. It covers data collected both at the point of account registration and throughout the ongoing relationship between 09bb and a registered player.

We are mindful that our players in Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, and other regions of Bangladesh trust us with sensitive personal and financial information. Maintaining that trust through responsible data practices is a core operational commitment at 09bb.

2. Data Controller

For the purposes of this Privacy Policy, 09bb acts as the data controller in respect of personal data collected from players through the platform. As data controller, 09bb determines the purposes and means by which personal data is processed. Any queries regarding the exercise of data rights, requests for data copies, or complaints about data handling practices should be directed to:

• Contact: [email protected]
• Subject Line: "Privacy — Data Controller Enquiry"
• Response Time: Within 30 days of receipt

Where 09bb engages third-party service providers to process personal data on its behalf, those providers act as data processors under contractual obligations that require them to process data only according to 09bb's documented instructions and to maintain appropriate security standards.

3. Data We Collect

The personal data 09bb collects can be grouped into the following categories:

3.1 Registration and Identity Data

When you create a 09bb account, we collect: your chosen username, a hashed version of your chosen password (plaintext passwords are never stored), the mobile phone number used to register, your full legal name (provided during identity verification), your date of birth, and the MFS wallet details (bKash, Nagad, Rocket, or Upay number) associated with your account for deposits and withdrawals.

3.2 Identity Verification Data

To comply with our age verification and anti-fraud obligations, 09bb may request copies of government-issued identity documents such as a National Identity Card (NID), passport, or birth certificate. Where a residential address must be verified, a recent utility bill or bank statement may also be requested. These documents are used solely for verification purposes and are stored securely with restricted access.

3.3 Transaction and Financial Data

We record all financial transactions associated with your account, including deposit amounts, deposit timestamps, withdrawal requests and processing dates, bonus credits and deductions, game wagering records, win and loss amounts, and the MFS wallet reference numbers associated with each transaction. Transaction records are maintained in detail for a minimum of five years.

3.4 Gaming Activity Data

09bb logs your activity on the platform including: games played, bet amounts, session start and end times, game outcomes, sports betting selections and odds accepted, bonus wagering progress, and responsible gaming tool usage (such as deposit limit settings or self-exclusion requests). This data is used to deliver a personalised experience, identify responsible gaming concerns, and detect unusual betting patterns.

3.5 Technical and Device Data

When you access 09bb, our servers automatically collect certain technical information including: your IP address, browser type and version, operating system, device type (mobile, tablet, or desktop), referring URL, pages visited on the platform, time spent on each page, and session duration. This data is used for security monitoring, platform optimisation, and fraud detection.

3.6 Communications Data

Records of all communications between you and the 09bb support team are retained, including live chat transcripts, email correspondence, and any feedback or complaint submissions. These records are used to resolve disputes, improve service quality, and maintain an audit trail of player interactions.

4. How Data Is Collected

09bb collects personal data through the following mechanisms:

• Direct submission: Data you provide voluntarily during registration, identity verification, support communications, or when updating your account profile.
• Automated collection: Technical and device data collected automatically by our servers when you visit or interact with the platform.
• Transaction processing: Financial data generated when you make deposits or withdrawals through bKash, Nagad, Rocket, or Upay.
• Cookies and similar technologies: Behavioural and session data collected through browser cookies and local storage (see Section 11).
• Third-party verification services: Identity and age verification data obtained from document verification partners when you submit identity documents for account verification.
• Game providers: Aggregate game performance data shared by licensed game studios (Pragmatic Play, NetEnt, Evolution Gaming, Ezugi, etc.) in connection with games played on the platform.

5. Purposes of Processing

09bb processes personal data for the following clearly defined purposes:

Purpose	Data Categories Used
Account registration and management	Registration data, identity data
Age and identity verification	Identity verification data, registration data
Processing deposits and withdrawals	Transaction data, MFS wallet details
Delivering and personalising game content	Gaming activity data, technical data
Fraud detection and prevention	All categories
Responsible gaming monitoring and intervention	Gaming activity data, registration data
Customer support delivery	Communications data, registration data
Legal and regulatory compliance	All categories as required
Platform security and performance	Technical and device data
Marketing and promotional communications (where consent given)	Registration data, gaming activity data

6. Legal Basis for Processing

09bb processes personal data on the following legal grounds:

• Contractual necessity: Processing required to register your account, manage your player relationship, process transactions, and deliver the core services of the platform.
• Legitimate interests: Processing conducted for fraud prevention, security monitoring, responsible gaming oversight, platform performance optimisation, and service improvement — where those interests are not overridden by the rights and interests of the data subject.
• Legal obligation: Processing required to comply with applicable record-keeping, anti-money laundering, and age verification obligations.
• Consent: Processing for direct marketing communications, where you have provided explicit opt-in consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

7. Data Sharing

09bb does not sell, rent, or trade your personal data to any third party for commercial purposes. Personal data is shared only in the following limited circumstances:

7.1 Payment Processing Partners

To process deposits and withdrawals, 09bb shares necessary transaction details with the relevant MFS provider (bKash, Nagad, Rocket, or Upay). The data shared is limited to what is strictly required to execute and confirm the transaction. MFS providers are independent data controllers subject to their own privacy policies and regulated under Bangladesh Bank's mobile financial services framework.

7.2 Identity Verification Providers

Where a player submits identity documents for account verification, those documents are transmitted to a contracted identity verification partner. This partner processes the documents solely for the purpose of confirming the player's identity and age on behalf of 09bb and is prohibited from using the data for any other purpose.

7.3 Game Software Providers

Licensed game studios whose titles are hosted on the 09bb platform may receive anonymised or pseudonymised game session data to support game performance monitoring, RNG auditing, and responsible gaming detection tools. No directly identifiable personal data (such as full name, NID number, or MFS wallet number) is shared with game providers.

7.4 Legal and Regulatory Disclosure

09bb may disclose personal data where required to do so by a valid legal order, court directive, or request from a competent government or law enforcement authority. In such cases, 09bb will disclose only the minimum data necessary to satisfy the legal requirement and will, where permitted by law, notify the affected player of the disclosure.

7.5 Business Transfers

In the event that 09bb undergoes a merger, acquisition, restructuring, or sale of assets, player personal data may form part of the transferred assets. In such circumstances, 09bb will ensure that the successor entity is bound by data protection obligations at least equivalent to those in this Privacy Policy, and will notify affected players via the registered contact detail associated with their account prior to any such transfer taking effect.

8. International Data Transfers

Given that 09bb's infrastructure and some of its third-party service providers may be located outside Bangladesh, your personal data may be transferred to and processed in countries other than Bangladesh. In all such cases, 09bb takes steps to ensure that appropriate safeguards are in place to protect your data, including contractual clauses that require recipient parties to maintain data protection standards comparable to those applied by 09bb.

If you have questions about the specific countries to which your data may be transferred or the safeguards in place, please contact [email protected].

9. Data Retention

09bb retains personal data for the following periods:

• Active account data: Retained for the duration of the active player relationship plus a minimum of five years following account closure.
• Transaction and financial records: Retained for a minimum of seven years to meet financial record-keeping obligations, which may extend beyond the five-year base period.
• Identity verification documents: Retained for five years following the completion of the verification process or account closure, whichever is later.
• Support communications: Retained for three years from the date of each communication, unless the communication relates to an open dispute in which case records are retained until the dispute is fully resolved and for two years thereafter.
• Technical and device logs: Retained for 12 months on a rolling basis, after which older log entries are automatically purged.
• Marketing consent records: Retained for as long as the consent remains valid plus three years following withdrawal of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or, where deletion is not technically feasible, anonymised such that it can no longer be attributed to any identifiable individual.

10. Security Measures

09bb implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure:

• Transport Layer Security: All data transmitted between your device and 09bb servers is encrypted using TLS 1.2 or higher. The padlock indicator in your browser confirms an encrypted connection is active.
• Password hashing: Account passwords are never stored in plaintext. They are processed through a one-way cryptographic hash function before storage, meaning that even 09bb personnel cannot read your password.
• Access controls: Access to player data is restricted to authorised 09bb personnel who require that access to fulfil their specific job functions. All access is logged and subject to regular audit.
• Encryption at rest: Sensitive data categories including identity documents and financial records are stored in encrypted form on 09bb's servers.
• Penetration testing: 09bb's technical infrastructure is subject to periodic security assessments conducted by independent security professionals.
• Incident response: 09bb maintains a documented data breach response procedure. In the event of a confirmed data breach affecting player personal data, affected players will be notified as promptly as practicable.

11. Cookies & Tracking Technologies

09bb uses cookies and similar technologies (such as browser local storage and session storage) to operate and improve the platform. The types of cookies used are described below:

• Strictly necessary cookies: These are essential for the platform to function and cannot be disabled. They include session authentication cookies that keep you logged in during your visit and security tokens that protect against cross-site request forgery.
• Functional cookies: These remember your preferences such as language settings and game display configurations, improving your experience on return visits.
• Analytics cookies: These collect anonymised information about how players use the platform — including which games are most popular, how long sessions last, and where errors occur — to help 09bb improve its services. This data is aggregated and does not identify individual players.
• Session cookies: These are temporary and are automatically deleted when you close your browser. They are used to maintain the state of your current session on the platform.

09bb does not use third-party advertising cookies or permit external advertising networks to place tracking cookies on the platform. You may adjust your browser settings to refuse cookies; however, disabling strictly necessary cookies will prevent you from logging into your 09bb account.

12. Your Data Rights

As a player on 09bb, you hold the following rights in respect of your personal data. To exercise any of these rights, submit a written request to [email protected] with the subject line "Privacy — Data Rights Request". 09bb will respond within 30 days.

09bb may request proof of identity before processing a data rights request to ensure that personal data is not disclosed to an unauthorised third party. Where a request is refused in whole or in part, 09bb will provide written reasons for the refusal.

13. Minors & Age Policy

The 09bb platform is strictly for adults aged 21 years and above. 09bb does not knowingly collect or process personal data relating to individuals under the age of 21. If 09bb discovers or is notified that personal data of a player under 21 has been collected, the relevant account will be immediately suspended, the data will be deleted (subject to any fraud investigation requirements), and any funds in the account will be returned to the originating MFS wallet.

If you believe that a person under the age of 21 has registered an account on 09bb, please notify us immediately at [email protected] with the subject line "Underage Account Report".

14. Marketing Communications

With your explicit consent, 09bb may contact you with promotional information about new games, bonus offers, seasonal promotions (including Eid special offers, Pohela Boishakh promotions, and BPL betting events), and platform updates. Marketing communications are sent via the mobile number or communication channel registered to your account.

You may withdraw your consent to receive marketing communications at any time by contacting [email protected] with the subject line "Unsubscribe — Marketing". Following receipt of your withdrawal request, 09bb will cease sending marketing communications within 5 business days. Withdrawal of marketing consent does not affect your ability to continue using the platform or receiving transactional and account-related notifications, which are sent on the basis of contractual necessity rather than consent.

09bb does not use personal data to build profiles for sale to third-party marketers, and does not permit third-party advertisers to target 09bb players using data sourced from the platform.

15. Changes to This Privacy Policy

09bb reserves the right to update this Privacy Policy periodically to reflect changes in our data processing practices, platform features, or applicable legal requirements. Where changes are material — meaning they affect how personal data is used or what rights players hold — 09bb will provide at least 14 days' advance notice by publishing an updated version of this policy on the platform and, where practicable, sending a notification to the contact detail registered to each affected account.

The "Last Updated" date at the top of this policy reflects the date on which the most recent version came into effect. We encourage players to review this policy periodically. Continued use of the platform after the effective date of any updated policy constitutes acceptance of the revised terms.

16. Contact Us

For all privacy-related enquiries — including data rights requests, questions about this policy, or complaints about how 09bb handles your personal data — please contact:

• Email: [email protected]
• Subject Line: "Privacy Enquiry" (for general questions) or "Privacy — Data Rights Request" (for formal rights requests)
• Response Time: Within 30 days of receipt for formal rights requests; within 2 business days for general privacy questions
• Support Hours: 24 hours a day, 7 days a week
• Languages: English and Bengali

09bb is committed to resolving privacy concerns promptly and transparently. If you are not satisfied with our response to a privacy complaint, you may seek independent advice or escalate the matter through whatever dispute resolution mechanisms are available in your jurisdiction.