Privacy Policy

club99 ("we", "us", "our", "the Platform") operates the online casino and sports betting website accessible at https://club99.vu. We serve players across Bangladesh who wish to enjoy cricket betting, live casino games, slots, and related entertainment services. club99 is the data controller responsible for the personal information collected through this platform.

This Privacy Policy sets out how club99 collects, processes, stores, shares, and protects the personal data of all visitors and registered account holders ("you", "your", "the Player") in connection with your use of the platform. It should be read alongside our Terms & Conditions and our Responsible Gaming policy.

club99 collects personal data across several categories depending on the nature of your interaction with the platform. The table below summarises the categories of data we may hold about you:

club99 collects personal data through the following channels:

• Direct interactions: When you register an account, complete the KYC verification process, make a deposit or withdrawal, place a bet, contact customer support, or respond to a promotion, you directly provide us with personal data.
• Automated technologies: When you visit the club99 website, our servers automatically log technical data including your IP address, browser type, device identifier, and session timestamps. Cookies and similar tracking technologies also collect usage data as described in Section 8.
• Payment processors: When you initiate a financial transaction, our payment processing partners (including the operators of bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Visa, and Mastercard gateway services) may share transaction confirmation data and wallet identifiers with club99 for the purpose of reconciling deposits and withdrawals.
• Identity verification providers: club99 may use third-party KYC service providers to verify the authenticity of identity documents submitted during account verification. These providers process document images on club99's behalf under strict data processing agreements.
• Fraud prevention and security partners: club99 works with specialist fraud detection services that may provide risk scores and device fingerprint data associated with account activity to help identify and prevent fraudulent behaviour.
• Publicly available sources: In limited circumstances related to AML due diligence, club99 may consult publicly available sources such as sanctions lists, politically exposed persons (PEP) databases, or adverse media sources to fulfil its compliance obligations.

club99 processes your personal data on one or more of the following legal bases depending on the specific processing activity:

• Contract performance: Processing is necessary for club99 to fulfil its obligations to you under the Terms & Conditions, including creating and managing your account, processing deposits and withdrawals, and providing access to betting and gaming services.
• Legal obligation: Processing is required for club99 to comply with applicable legal and regulatory requirements, including anti-money laundering (AML) obligations, age verification requirements, and the retention of financial transaction records.
• Legitimate interests: Processing is carried out for the legitimate interests of club99 or third parties, including platform security, fraud prevention, responsible gaming monitoring, service improvement, and the detection and investigation of prohibited conduct — provided that such interests are not overridden by your fundamental rights and freedoms.
• Consent: Where club99 processes personal data for optional purposes — such as sending you promotional communications about bonuses, BPL cricket promotions, IPL offers, or seasonal campaigns for Eid or Pohela Boishakh — it does so on the basis of your freely given, specific, and informed consent. You may withdraw consent at any time by updating your communication preferences in your account settings or contacting [email protected].

club99 uses the personal data it collects for the following specific purposes:

• To create, manage, and maintain your club99 player account, including processing your registration and verifying your identity.
• To process financial transactions, including deposits via bKash, Nagad, Rocket, Upay, and bank channels, and to process withdrawal requests to your registered payment method.
• To conduct age verification and Know Your Customer (KYC) checks in compliance with applicable obligations, and to prevent access by individuals under 18 years of age.
• To detect, investigate, and prevent fraudulent activity, money laundering, account takeover attempts, collusion, and other prohibited conduct as defined in the Terms & Conditions.
• To provide customer support, respond to your enquiries and complaints, and maintain records of your support interactions for quality assurance purposes.
• To monitor your gaming activity for responsible gaming purposes, including identifying patterns that may indicate problem gambling behaviour, and to apply any responsible gaming tools you have activated such as deposit limits, cool-off periods, or self-exclusion.
• To personalise your experience on the club99 platform, including presenting relevant games, sports markets, and promotional offers based on your usage history (where you have not opted out of personalisation).
• To send you transactional communications such as deposit confirmations, withdrawal notifications, account security alerts, and important service updates. These communications are not optional and will be sent regardless of your marketing preferences.
• To send you promotional communications about bonuses, free bets, cricket betting markets, casino promotions, and seasonal campaigns — but only where you have opted in to receive such communications or where permitted by applicable law.
• To fulfil our legal and regulatory obligations, including the retention and provision of records to relevant authorities in response to lawful requests.
• To improve the club99 platform by analysing aggregated usage data, testing new features, and optimising platform performance and user experience.

club99 does not sell, rent, or trade your personal data. We may share your personal information with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment service providers: Operators of bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, and Visa/Mastercard payment gateways, to the extent necessary to process your financial transactions.
• Identity verification and KYC providers: Third-party providers engaged to verify the authenticity of identity documents and conduct age verification checks on club99's behalf.
• Fraud prevention and security services: Specialist providers of fraud detection, device fingerprinting, and risk scoring services used to protect the integrity of the platform and its players.
• Game technology providers: Software providers including Pragmatic Play, Evolution Gaming, Ezugi, Spribe, NetEnt, and Microgaming may receive limited technical session data (such as player session tokens) to the extent required to deliver their games within the club99 platform. These providers do not receive your full identity or financial data.
• IT infrastructure and hosting providers: Cloud and server infrastructure providers that host the club99 platform and process data on our behalf under strict data processing agreements.
• Legal and regulatory authorities: club99 may disclose personal data to law enforcement agencies, regulatory bodies, courts, or other government authorities where required to do so by law, or where such disclosure is necessary to protect the rights, property, or safety of club99 or its players.
• Professional advisers: Lawyers, auditors, and other professional advisers engaged in connection with club99's business operations, subject to professional obligations of confidentiality.

club99 operates as an international online gaming platform serving players primarily in Bangladesh. As a result, personal data processed by club99 may be transferred to and stored on servers located outside Bangladesh, including in other jurisdictions where our technology infrastructure providers and game software partners are based.

Whenever personal data is transferred internationally, club99 takes appropriate steps to ensure that your data receives an adequate level of protection, including:

• Conducting data transfers only to countries or entities that offer an adequate level of data protection as assessed by club99 and its legal advisers.
• Implementing contractual data processing agreements with international service providers that incorporate appropriate data protection clauses and security obligations.
• Applying technical safeguards including encryption in transit and at rest to all internationally transferred data.

By registering an account and using the club99 platform, you acknowledge that your personal data may be processed in jurisdictions outside Bangladesh as described in this section.

club99 uses cookies — small text files stored on your device — and similar tracking technologies to support the operation, security, and performance of the platform. The following categories of cookies are used:

You can manage cookies through your browser settings at any time. Note that disabling non-essential cookies may affect the quality of your experience on the platform but will not prevent you from accessing core services. club99 does not use cookies to deliver third-party advertising or track your activity across other websites.

club99 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention periods apply:

• Active account data: Retained throughout the period your account remains open and active on the platform.
• Closed account data: Following account closure, identity and financial transaction records are retained for a minimum of five years in compliance with AML and financial record-keeping obligations. This period may be extended if a legal investigation or dispute is ongoing at the time of closure.
• KYC and identity documents: Retained for a minimum of five years from the date of submission or from the date of account closure, whichever is later.
• Support communications: Email and live chat records are retained for a minimum of two years from the date of the interaction, or longer if the communication relates to an unresolved dispute or compliance matter.
• Technical and usage logs: Server logs and session data are typically retained for 12 months and then purged or anonymised unless required for an ongoing investigation.
• Marketing consent records: Records of your consent to receive promotional communications are retained for as long as you hold an active account, and for a minimum of two years after account closure.

At the end of the applicable retention period, personal data is securely deleted or permanently anonymised in a manner that prevents reconstruction of your identity.

club99 implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• SSL/TLS encryption: All data transmitted between your browser or app and the club99 servers is encrypted using industry-standard TLS (Transport Layer Security) protocols.
• Encryption at rest: Sensitive personal data — including identity documents, financial account details, and passwords — is stored in encrypted form on club99's servers using strong cryptographic algorithms.
• Access controls: Access to personal data within club99's internal systems is restricted on a strict need-to-know basis. Staff members are granted the minimum level of access necessary to perform their roles, and all access to sensitive data is logged and monitored.
• Two-factor authentication: club99 offers two-step account verification via SMS OTP to all registered players and enforces it internally for staff accessing sensitive systems.
• Regular security assessments: club99 conducts periodic security reviews, vulnerability assessments, and penetration testing to identify and remediate potential weaknesses in the platform's infrastructure.
• Incident response: club99 maintains a documented data breach response procedure. In the event of a security incident that poses a material risk to your personal data, club99 will notify affected players and take appropriate remedial action without undue delay.

As a player registered on the club99 platform, you hold the following rights in relation to the personal data we hold about you. To exercise any of these rights, contact us at [email protected] with a clear description of your request. We will respond within a reasonable timeframe and in any event within 30 days of receipt of your request.

• Right of access: You have the right to request a copy of the personal data club99 holds about you, together with information about the purposes for which it is processed and the categories of recipients with whom it has been shared.
• Right to rectification: If any of the personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected or updated. You may also update certain personal information directly from your account settings panel.
• Right to erasure: In certain circumstances — for example, where the data is no longer necessary for the purposes for which it was collected and club99 is not subject to a legal obligation to retain it — you have the right to request that your personal data be deleted. Note that this right may be limited where retention is required for AML compliance or to defend a legal claim.
• Right to restriction of processing: In certain circumstances, you may request that club99 restrict the processing of your personal data, for example while a dispute over the accuracy of the data is being resolved.
• Right to data portability: Where processing is based on your consent or on the performance of a contract, you have the right to receive a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to withdraw consent: Where club99 processes your personal data on the basis of your consent (for example, for marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing that took place prior to withdrawal.
• Right to object: You have the right to object to processing carried out on the basis of club99's legitimate interests. club99 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or where processing is necessary for the establishment, exercise, or defence of legal claims.

The club99 platform is strictly intended for adults aged 18 and above. club99 does not knowingly collect, process, or store personal data relating to individuals under the age of 18. Registration is not permitted for individuals who are under 18 years of age, and club99 employs age verification measures to enforce this requirement.

If club99 becomes aware that it has inadvertently collected personal data from an individual under the age of 18, it will take immediate steps to delete such data and close the associated account. If you are a parent or guardian and believe that your child may have registered an account on the club99 platform, please contact us immediately at [email protected] so that we can investigate and take appropriate action.

The club99 platform may contain references to third-party services, including the payment partner brands listed in our Accepted Payments section (bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Visa, and Mastercard) and game software providers (including Pragmatic Play, Evolution Gaming, Ezugi, Spribe, NetEnt, and Microgaming).

club99 does not control the privacy practices of these third-party organisations and is not responsible for the content, privacy policies, or security practices of any external platform or service. When you interact with a third-party payment provider to initiate a transaction, you are subject to that provider's own terms of service and privacy policy, which club99 encourages you to review independently.

This Privacy Policy applies solely to personal data collected and processed by club99 through the club99 website at https://club99.vu and does not extend to any third-party platforms or services accessed via external links.

club99 reserves the right to update or revise this Privacy Policy at any time. When a material change is made to the Policy, club99 will endeavour to provide reasonable advance notice to registered account holders via the email address associated with their account or via a notice displayed on the platform.

The most current version of this Privacy Policy will always be published at https://club99.vu/privacy-policy. The "Last Updated" date shown at the top of this page reflects the date on which the most recent revision came into effect.

Your continued use of the club99 platform following the publication of any updated Privacy Policy constitutes your acknowledgement of the revised terms. If you do not agree with any change to this Policy, you should cease using the platform and contact [email protected] to close your account.

If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data club99 holds about you, please contact our support team using the details set out below. All privacy-related communications should be directed to the support email address and clearly marked with the subject "Privacy Request" or "Data Protection Enquiry" to ensure prompt handling.

• Support Email: [email protected] (plain text — not a clickable link)
• Response Time: Privacy and data subject requests are acknowledged within 3 business days and fully responded to within 30 calendar days.
• Support Hours: 24 hours a day, 7 days a week, including public holidays observed in Bangladesh.
• Time Zone: Bangladesh Standard Time (BST, UTC+6).

For account closure requests, self-exclusion requests, or withdrawal of marketing consent, please state the nature of your request clearly in your email subject line so that it is routed to the correct internal team without delay.