ph9999 Privacy Policy

1 Introduction

This Privacy Policy ("Policy") sets out the principles and practices by which ph9999 ("the Company", "we", "us", "our") collects, processes, stores, and protects the personal data of individuals ("Players", "Users", "you", "your") who access or use the services available at ph9999.today and all associated sub-domains and mobile interfaces (collectively, "the Platform").

ph9999 operates as an online gaming platform serving the Bangladesh market, offering sports betting, live casino games, slot titles, and specialty gaming products. In the course of providing these services, ph9999 necessarily collects and processes a range of personal data about registered players and visitors to the Platform.

ph9999 is committed to handling all personal data responsibly, transparently, and in accordance with applicable data protection principles. We do not sell, rent, or trade personal data with unaffiliated third parties for their independent marketing purposes. All data collected by ph9999 is used solely in connection with the provision, improvement, and protection of our gaming services and in fulfilment of our legal obligations.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, both of which form part of the overall agreement between you and ph9999. In the event of any conflict between this Policy and those documents, the Terms & Conditions shall take precedence on matters of contract, while this Policy governs all data-specific matters.

2 Data We Collect

ph9999 collects personal data through several channels: directly from you during registration and account activity, automatically through your use of the Platform, and in limited circumstances from third parties during the verification process.

ph9999 does not knowingly collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data (except where voluntarily provided in connection with a responsible gaming self-exclusion request), or biometric identifiers.

3 How We Use Your Data

ph9999 uses the personal data we collect for clearly defined purposes. We do not use your data in any manner that is incompatible with the purposes for which it was originally collected. The primary purposes for which ph9999 processes player data are as follows:

• Account Registration and Management: To create, maintain, and administer your ph9999 player account, including verifying your identity and eligibility to use our services.
• Service Delivery: To provide you with access to sports betting, live casino, slots, and all other gaming products available on the Platform, and to process your bets, winnings, and account transactions accurately.
• Payment Processing: To facilitate deposits and withdrawals via your chosen payment method (including bKash, Nagad, Rocket, Upay, and supported banks), and to maintain accurate financial records in connection with your account.
• Identity Verification and KYC Compliance: To verify your identity, age, and residential location in Bangladesh in accordance with our Know Your Customer (KYC) obligations and to prevent fraud, money laundering, and underage gambling.
• Responsible Gaming: To monitor account activity for indicators of problem gambling behaviour, to enforce player-set limits and self-exclusion instructions, and to offer proactive responsible gaming interventions where warranted.
• Customer Support: To respond to your enquiries, complaints, and support requests, and to maintain a record of communications between you and ph9999 for quality assurance and dispute resolution purposes.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, account takeover attempts, bonus abuse, and other prohibited activities on the Platform.
• Legal and Regulatory Compliance: To comply with applicable laws, respond to lawful requests from authorities, and fulfil our record-keeping obligations.
• Platform Improvement: To analyse aggregated usage data (in anonymised or pseudonymised form) for the purposes of improving Platform performance, user experience, game selection, and service quality.
• Marketing Communications: Where you have provided explicit consent, to send you promotional offers, bonus notifications, and updates about new games or features on ph9999. You may withdraw consent for marketing communications at any time by contacting [email protected].

4 Legal Basis for Processing

ph9999 processes your personal data on the following legal grounds depending on the specific purpose of processing:

• Contractual Necessity: Processing required to fulfil our obligations under the Terms & Conditions you agreed to upon registering your account, including account management, service delivery, and payment processing.
• Legal Obligation: Processing necessary for ph9999 to comply with applicable legal and regulatory requirements, including anti-money-laundering (AML) obligations, age verification requirements, and responses to lawful authority requests.
• Legitimate Interests: Processing carried out in pursuit of ph9999's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and internal analytics — where such interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent, primarily in connection with marketing communications. Where consent is the legal basis, you have the right to withdraw it at any time without affecting the lawfulness of prior processing.

5 Data Sharing

ph9999 does not sell, rent, or trade your personal data with unaffiliated third parties for their independent commercial use. However, in order to operate the Platform effectively and comply with our legal obligations, we may share your data with the following categories of recipients:

• Payment Service Providers: We share necessary financial data with your chosen payment provider (such as bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, City Bank, and other supported channels) solely to process your deposits and withdrawals. These providers operate under their own privacy policies and data security standards.
• Identity Verification Partners: We may engage third-party KYC and identity verification service providers to assist in verifying player identity documents and cross-checking against relevant databases, where required for compliance purposes.
• Game Content Providers: Game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi may receive limited technical data (such as session tokens and game round identifiers) necessary for the delivery of their gaming content on the ph9999 Platform. These providers are bound by strict data processing agreements.
• Fraud and Security Vendors: We may share technical data (such as IP address, device fingerprint, and transaction patterns) with specialist fraud detection and cybersecurity service providers to protect the integrity of the Platform and its players.
• Legal and Regulatory Authorities: ph9999 will disclose player data to law enforcement agencies, regulatory bodies, or courts where required to do so by applicable law, court order, or lawful government request. ph9999 will not notify the player of such disclosure where doing so would be unlawful or would prejudice an ongoing investigation.
• Business Successors: In the event of a merger, acquisition, or transfer of substantially all of ph9999's assets to a successor entity, player data may be transferred as part of that transaction. Players will be notified in advance of any such transfer where required by applicable law.

6 Data Retention

ph9999 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. Our standard retention periods are as follows:

• Active Account Data: Personal data associated with an active player account is retained for the full duration of the account relationship and for a minimum period of five (5) years following permanent account closure, in accordance with standard AML record-keeping requirements.
• Transaction Records: Financial transaction records, including deposit and withdrawal history, are retained for a minimum of five (5) years from the date of each transaction.
• KYC Documents: Identity verification documents are retained for a minimum of five (5) years following account closure or the date of the last transaction, whichever is later.
• Support Communications: Customer support correspondence is retained for a minimum of two (2) years from the date of the last communication in a given ticket or thread.
• Marketing Consent Records: Where you have consented to receive marketing communications, a record of that consent is retained for the duration of the marketing relationship and for one (1) year following your withdrawal of consent.
• Technical and Log Data: Server log data and technical access records are retained for up to twelve (12) months from the date of collection, unless a longer period is required for an ongoing fraud investigation or legal proceeding.

Following the expiry of the applicable retention period, personal data will be securely deleted or anonymised so that it can no longer be associated with an identifiable individual.

7 Data Security

ph9999 implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. Our security framework includes the following measures:

• SSL/TLS Encryption: All data transmitted between your device and the ph9999 Platform is protected by industry-standard SSL/TLS encryption. This ensures that your login credentials, payment information, and personal details cannot be intercepted during transmission.
• Encrypted Data Storage: Sensitive personal data held in our databases — including identity documents and payment details — is stored in encrypted form using industry-recognised encryption standards.
• Access Controls: Access to personal data within ph9999's internal systems is strictly limited to authorised personnel who require that data to perform their job functions. All staff with access to player data are subject to confidentiality obligations.
• Secure Payment Infrastructure: ph9999 does not store full payment credentials such as complete bank account numbers or mobile wallet PINs. Payment transactions are processed via the secure APIs of our payment partners.
• Intrusion Detection and Monitoring: ph9999 employs continuous monitoring and intrusion detection systems to identify and respond to potential security threats in real time.
• Password Security: Player account passwords are stored in hashed form and are never stored or transmitted in plain text. ph9999 will never ask you to reveal your password via email, live chat, or phone.

While ph9999 takes all reasonable precautions to secure your personal data, no system connected to the internet can be guaranteed to be completely secure. In the event of a data security breach that is likely to result in a high risk to your rights and freedoms, ph9999 will notify affected players as promptly as reasonably practicable.

8 Cookies & Tracking Technologies

ph9999 uses cookies and similar tracking technologies on the Platform to enhance user experience, maintain session integrity, and collect analytical data. The categories of cookies we use are as follows:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function and cannot be disabled. They include session cookies that keep you logged in during your visit, security tokens, and cookies that remember your language and regional preferences.
• Analytical / Performance Cookies: These cookies collect aggregated, anonymised data about how players use the Platform — such as which pages are visited most frequently and how long sessions last. This information helps ph9999 improve Platform performance and content. No personally identifiable information is stored in these cookies.
• Functionality Cookies: These cookies remember preferences you have set on the Platform (such as game display settings) to provide a more personalised experience on return visits.
• Marketing Cookies: Where you have consented to marketing, these cookies may be used to track whether you have interacted with promotional materials and to measure the effectiveness of ph9999's campaigns. You may opt out of marketing cookies by contacting [email protected].

Most web browsers allow you to control cookie settings through their preference or settings menus. Please be aware that disabling certain cookies may affect the functionality of the ph9999 Platform, including your ability to remain logged in or complete transactions.

9 Your Rights

As a player on ph9999, you hold the following rights in relation to the personal data we hold about you. To exercise any of these rights, please contact our support team at [email protected]:

• Right of Access: You have the right to request a copy of the personal data ph9999 holds about you, along with information about how that data is being used. We will respond to verified access requests within a reasonable timeframe.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You may also update certain personal details directly through your account dashboard.
• Right to Erasure: In certain circumstances, you may request that ph9999 delete the personal data we hold about you. Please note that this right is subject to overriding legal obligations — for example, we are required to retain financial transaction records for a minimum period as described in Section 6. Where deletion is not possible in full, we will explain the applicable limitation.
• Right to Restriction of Processing: You may request that ph9999 restrict the processing of your personal data in certain circumstances — for example, while a dispute about the accuracy of your data is being resolved.
• Right to Data Portability: Where processing is based on your consent or on a contract, and is carried out by automated means, you have the right to receive the personal data you provided to ph9999 in a structured, commonly used, machine-readable format.
• Right to Withdraw Consent: Where processing is based on your consent (most commonly for marketing communications), you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.
• Right to Object: You have the right to object to ph9999's processing of your personal data where that processing is based on our legitimate interests, including for direct marketing purposes.

ph9999 will respond to all rights requests within 30 days of receipt. In complex cases, this period may be extended by a further 30 days, in which case we will notify you of the extension and the reason for it.

10 Minors

ph9999 services are strictly intended for adults aged 18 and above. We do not knowingly collect, process, or store personal data from individuals under the age of 18. If you are under 18 years of age, you must not use the ph9999 Platform or provide any personal data to us.

If ph9999 becomes aware or has reasonable grounds to believe that personal data has been collected from a person under 18, we will take immediate steps to delete that data and close the associated account. If you are a parent or guardian and believe that your child has provided personal data to ph9999 without your consent, please contact us immediately at [email protected].

For full details of our approach to protecting minors from gambling harm, please visit our Responsible Gaming page.

11 Third-Party Links & Content

The ph9999 Platform hosts gaming content provided under licence from third-party game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi, among others. While ph9999 has entered into data processing agreements with these providers, please be aware that interactions within third-party game environments may be subject to those studios' own privacy practices in addition to this Policy.

ph9999 is not responsible for the privacy practices or content of any third-party websites, platforms, or services that are not directly operated by ph9999. We encourage you to review the privacy policies of any third-party service you interact with in connection with your gaming activity.

12 Changes to This Policy

ph9999 reserves the right to amend or update this Privacy Policy at any time. Any material changes to this Policy will be communicated to registered players via email or through an on-Platform notification, and the updated Policy will be published on this page with a revised effective date.

Your continued use of the ph9999 Platform following the publication of a revised Privacy Policy constitutes your acceptance of the updated terms. We recommend reviewing this page periodically to stay informed of any changes to our data practices. If you disagree with any changes to this Policy, you must cease using the Platform and may request account closure in accordance with the Terms & Conditions.

13 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the manner in which ph9999 processes your personal data, our dedicated support team is available 24 hours a day, 7 days a week.

You may reach us by email at: [email protected]

Please include "Privacy Request" in the subject line of your email so that it is directed promptly to the appropriate team. We aim to acknowledge all privacy-related enquiries within one Bangladesh business day (Bangladesh Standard Time, UTC+6) and to provide a substantive response within 30 calendar days.

For matters relating specifically to responsible gambling, self-exclusion, or deposit limits, please also refer to our Responsible Gaming page for detailed guidance and available support tools.