Privacy & Data Protection

Club99 Privacy Policy

Your personal data belongs to you. This policy explains exactly what Club99 collects, why we collect it, how we protect it, and what rights you have over your own information. We keep it straightforward — no legal jargon where plain language will do.

Last Updated: January 2025

How Club99 Protects Your Data

A plain-language overview of our key privacy commitments before you read the full policy below.

Encrypted Data Storage

All personal data stored by Club99 is encrypted at rest using AES-256 encryption. Your account details, payment information, and gaming history are never stored in plain text. Access to stored data is restricted to authorised personnel only.

No Data Selling

Club99 does not sell, rent, or trade your personal data to third-party marketers under any circumstances. Your information is shared only with the service providers we need to operate the platform — payment processors, KYC providers, and fraud prevention services.

You Control Your Data

Club99 members have the right to access, correct, and request deletion of their personal data at any time. Submit a data request via [email protected] and we will respond within 30 days. Your data, your rules.

Secure Transmission

All data transmitted between your device and Club99 servers is protected by TLS 1.3 encryption. The padlock icon in your browser confirms that your connection to club99.fun is always secure. We never transmit sensitive data over unencrypted channels.

Defined Retention Periods

Club99 only keeps your data for as long as it is needed. Account data is retained for the duration of your membership plus 5 years for regulatory compliance. Transaction records are kept for 7 years as required by financial regulations. Data is securely deleted after retention periods expire.

Marketing Opt-Out

Club99 will only send you promotional communications if you have opted in during registration or via your account settings. You can unsubscribe from marketing emails at any time using the unsubscribe link in any email, or by updating your preferences in your Club99 account settings.

1 Who We Are

Club99 is an online gaming platform operated at club99.fun, serving players primarily in Bangladesh. When this Privacy Policy refers to "Club99", "we", "us", or "our", it means the Club99 platform and its operating team.

Club99 acts as the data controller for all personal data collected through the platform. This means we are responsible for deciding how and why your personal data is processed. If you have any questions about how Club99 handles your data, contact us at [email protected].

This Privacy Policy applies to all Club99 services including the website at club99.fun, the Club99 mobile app, and all customer support interactions.

2 Data We Collect

Club99 collects personal data in three main ways: information you provide directly, information generated by your use of the platform, and information received from third-party service providers.

2.1 Information You Provide

  • Full legal name and date of birth
  • Email address and phone number
  • Residential address
  • Government-issued ID documents (for KYC verification)
  • Payment method details (bKash number, Nagad number, bank account details)
  • Profile preferences and communication settings

2.2 Information Generated by Platform Use

  • Login timestamps and session duration
  • Device type, operating system, and browser information
  • IP address and approximate geographic location
  • Game activity, bet history, and transaction records
  • Bonus and voucher usage history
  • Customer support chat and email records

2.3 Information from Third Parties

  • Identity verification results from KYC providers
  • Fraud risk scores from fraud prevention services
  • Payment confirmation data from bKash, Nagad, and Rocket

Club99 does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health information unless specifically required for responsible gaming purposes.

2.4 Data We Do Not Collect

Club99 does not store full payment card numbers. When payment card details are used, they are processed directly by our payment provider and Club99 only receives a tokenised reference. We do not have access to your full card number at any point.

3 How We Use Your Data

Club99 uses your personal data only for legitimate purposes directly related to operating the platform and providing services to you. We do not use your data for purposes that are incompatible with the reasons it was originally collected.

Purpose Data Used
Account registration and management Name, email, phone, date of birth, address
Identity verification (KYC) ID documents, name, date of birth, address
Processing deposits and withdrawals Payment method details, transaction history
Fraud prevention and security monitoring IP address, device info, login history, transaction patterns
Customer support Account details, support chat and email records
Responsible gaming monitoring Gaming activity, session data, deposit and loss history
Regulatory compliance and AML screening Identity data, transaction records
Marketing communications (opt-in only) Email address, communication preferences
Platform improvement and analytics Anonymised usage data, device and browser info

4 Legal Basis for Processing

Club99 processes your personal data on one or more of the following legal bases depending on the specific purpose:

  • Contract performance: Processing necessary to provide the Club99 service you have signed up for, including account management, deposits, withdrawals, and game access.
  • Legal obligation: Processing required to comply with applicable laws, including anti-money laundering regulations, identity verification requirements, and financial record-keeping obligations.
  • Legitimate interests: Processing necessary for Club99's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your rights.
  • Consent: Processing based on your explicit consent, such as sending marketing emails or push notifications. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

5 Data Sharing

Club99 does not sell your personal data. We share data only with the categories of third parties listed below, and only to the extent necessary for the stated purpose.

5.1 Payment Processors

To process deposits and withdrawals, Club99 shares necessary transaction data with bKash, Nagad, Rocket, and other payment providers. These providers process data under their own privacy policies and are bound by contractual data protection obligations with Club99.

5.2 Identity Verification Providers

Club99 uses third-party KYC providers to verify the identity of members. Your ID documents and personal details are shared with these providers solely for the purpose of identity verification. KYC providers are contractually prohibited from using your data for any other purpose.

5.3 Fraud Prevention Services

Club99 uses fraud detection services that analyse account activity patterns to identify suspicious behaviour. These services may process your IP address, device fingerprint, and transaction data. This processing is carried out in Club99's legitimate interest of protecting the platform and its members.

5.4 Regulatory and Legal Disclosure

Club99 may be required to disclose personal data to regulatory authorities, law enforcement agencies, or courts where required by applicable law. Club99 will only disclose the minimum data necessary to comply with a legal obligation and will notify affected members where legally permitted to do so.

All third-party service providers used by Club99 are contractually required to implement appropriate data protection measures and are prohibited from using your data for their own commercial purposes.

6 Cookies & Tracking

Club99 uses cookies and similar tracking technologies to operate the platform, remember your preferences, and analyse how the site is used. A cookie is a small text file stored on your device when you visit club99.fun.

6.1 Types of Cookies We Use

  • Essential cookies: Required for the platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
  • Functional cookies: Remember your preferences such as language settings, display options, and game history. Disabling these may affect your experience on the platform.
  • Analytics cookies: Help Club99 understand how members use the platform so we can improve it. Analytics data is aggregated and anonymised where possible.
  • Security cookies: Used to detect and prevent fraudulent activity, including bot detection and account takeover prevention.

6.2 Managing Cookies

You can control non-essential cookies through your browser settings. Most browsers allow you to block or delete cookies. Note that blocking essential cookies will prevent you from logging in to your Club99 account. For detailed instructions on managing cookies in your specific browser, refer to your browser's help documentation.

7 Data Security

Club99 takes the security of your personal data seriously. We implement a layered security approach that includes both technical and organisational measures to protect your data against unauthorised access, loss, or disclosure.

7.1 Technical Measures

  • TLS 1.3 encryption for all data in transit between your device and Club99 servers
  • AES-256 encryption for all personal data stored at rest
  • Multi-factor authentication available for all Club99 accounts
  • Regular penetration testing and security audits by independent security firms
  • Automated intrusion detection and real-time threat monitoring
  • Segregated database architecture to limit data exposure in the event of a breach

7.2 Organisational Measures

  • Access to personal data is restricted to Club99 staff who need it to perform their job functions
  • All staff with access to personal data receive regular data protection training
  • Data access is logged and audited on a regular basis
  • Club99 has a documented data breach response procedure

7.3 Data Breach Notification

In the unlikely event of a data breach that poses a risk to your rights and freedoms, Club99 will notify affected members without undue delay and no later than 72 hours after becoming aware of the breach. The notification will describe the nature of the breach, the data affected, and the steps Club99 is taking to address it.

While Club99 implements strong security measures, no online platform can guarantee 100% security. You can help protect your account by using a strong, unique password and enabling two-factor authentication in your account settings.

8 Data Retention

Club99 retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following retention periods apply:

Data Category Retention Period Reason
Account registration data Duration of membership + 5 years Regulatory compliance
Transaction and payment records 7 years from transaction date Financial regulations
KYC identity documents 5 years after account closure AML regulations
Customer support records 3 years from last interaction Dispute resolution
Marketing consent records Until consent is withdrawn + 1 year Proof of consent
Analytics data (anonymised) 26 months Platform improvement

After the applicable retention period expires, personal data is securely deleted or anonymised so that it can no longer be linked to an individual. Anonymised data may be retained indefinitely for statistical and analytical purposes.

9 Your Privacy Rights

As a Club99 member, you have the following rights over your personal data. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request". We will respond within 30 days.

Right of Access

Request a copy of all personal data Club99 holds about you. We will provide this in a structured, commonly used format within 30 days of your request.

Right to Rectification

Request correction of any inaccurate or incomplete personal data. You can update most account details directly in your Club99 account settings without needing to contact support.

Right to Erasure

Request deletion of your personal data where it is no longer necessary for the purpose it was collected, or where you withdraw consent. Note that some data must be retained for legal compliance and cannot be deleted on request.

Right to Restrict Processing

Request that Club99 limits how your data is used while a dispute about its accuracy or the lawfulness of processing is being resolved.

Right to Data Portability

Request your personal data in a machine-readable format so you can transfer it to another service provider. This right applies to data you have provided to Club99 and that is processed by automated means.

Right to Object

Object to Club99 processing your data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, though Club99 may be able to demonstrate compelling grounds to continue processing.

10 Children's Privacy

Club99 is strictly an adults-only platform. We do not knowingly collect personal data from anyone under the age of 18. If you are under 18, you must not register an account or use the Club99 platform in any way.

If Club99 becomes aware that personal data has been collected from a person under 18, we will immediately close the account, delete the data, and return any deposits to the original payment method where possible. If you believe a minor has registered on Club99, please contact us immediately at [email protected].

Club99 uses age verification checks during registration and KYC to prevent underage access. We take our responsibility to protect minors seriously and support all industry initiatives aimed at preventing underage gambling.

11 Marketing Communications

Club99 will only send you promotional emails, SMS messages, or push notifications if you have explicitly opted in to receive them. You can manage your marketing preferences at any time through your Club99 account settings under "Communication Preferences".

11.1 How to Opt Out

  • Email: Click the "Unsubscribe" link at the bottom of any Club99 marketing email.
  • SMS: Reply STOP to any Club99 promotional SMS message.
  • Account settings: Update your communication preferences directly in your Club99 account dashboard.
  • Email request: Send an opt-out request to [email protected].

Opting out of marketing communications will not affect transactional messages such as deposit confirmations, withdrawal notifications, account security alerts, or important policy updates. These service messages are sent regardless of your marketing preferences as they are necessary for the operation of your account.

Opt-out requests are processed within 5 business days. You may receive one or two further messages while your request is being processed.

12 Changes to This Policy

Club99 may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or platform features. When we make material changes, we will notify registered members by email and display a prominent notice on the Club99 platform for at least 7 days before the changes take effect.

The "Last Updated" date at the top of this page indicates when the policy was most recently revised. We encourage you to review this policy periodically. Your continued use of Club99 after the effective date of any changes constitutes your acknowledgement of the updated policy.

If you have concerns about any changes to this Privacy Policy, you are welcome to contact us at [email protected] before the changes take effect. If you do not agree with the updated policy, you may request account closure and we will process your remaining real money balance back to your registered payment method.

13 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way Club99 handles your personal data, please get in touch with our team:

  • Email: [email protected]
  • Subject line for data requests: "Data Rights Request"
  • Live Chat: Available 24/7 via the chat icon on club99.fun
  • Response time: Within 30 days for formal data rights requests; within 4 hours for general privacy queries via email

For information about responsible gaming tools and support, visit our Responsible Gaming page. For general platform questions, visit our FAQ page.

Your Data Is Safe With Club99

Play With Confidence

Now you know exactly how Club99 protects your privacy. Register your account today and enjoy a secure, trusted gaming experience built for Bangladesh players.

18+ only. Please play responsibly. Full terms apply.