Your Privacy at cl99

cl99 is Bangladesh's premier online betting and casino platform, accessible at cl99.im. We are committed to protecting the privacy and personal data of every player who registers and uses our services. This Privacy Policy explains in plain English what personal information cl99 collects from you, the purposes for which it is processed, the legal bases upon which we rely, how long we keep it, and the rights available to you at any time.

This Privacy Policy applies to all data processing activities carried out by cl99 in connection with the operation of the cl99 platform, including account registration, identity verification, deposits and withdrawals, sports betting, casino game participation, customer support interactions, and promotional activity.

By creating a cl99 account and using our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein. If you do not agree to this policy, please do not register an account or use the cl99 platform.

cl99 collects personal data in two main categories: information you provide directly to us, and information we collect automatically through your use of the platform. The specific data points within each category are detailed below.

2.1 Data You Provide Directly

2.2 Data Collected Automatically

cl99 collects your personal data through the following channels:

• Direct submission: Information you enter into cl99 registration forms, KYC verification uploads, payment forms, live chat windows, and support ticket submissions.
• Automated collection: Technical and usage data collected automatically by cl99 servers and analytics tools each time you access the platform, including via mobile browser or desktop.
• Third-party payment processors: Transaction reference data and payment confirmation details received from bKash, Nagad, Rocket, Upay, and banking partners when you initiate a deposit or withdrawal.
• Identity verification providers: Where cl99 uses a third-party KYC service to verify your identity documents, that provider may return verification status and document authenticity results to cl99.
• Game providers: Aggregated game session data (wager amounts, session durations, game IDs) returned from third-party game studio APIs such as Pragmatic Play, Evolution Gaming, Spribe, and Ezugi, used for responsible gaming monitoring and dispute resolution.

cl99 processes your personal data only where a valid legal basis exists. The legal bases we rely upon are as follows:

• Contractual necessity: Processing your identity data, contact data, and financial data is necessary to perform the contract between you and cl99 — specifically, to register your account, verify your eligibility, process deposits and withdrawals, and operate your betting and gaming activity.
• Legal obligation: cl99 is required by applicable law and its operating licence conditions to collect and retain certain data for anti-money laundering (AML) compliance, fraud prevention, and age verification purposes.
• Legitimate interests: cl99 has legitimate interests in collecting technical and usage data to maintain platform security, prevent fraud, detect multi-accounting, and improve the overall quality of our services. These interests do not override your fundamental privacy rights.
• Consent: Where cl99 processes your personal data for marketing communications or optional analytics beyond what is operationally necessary, we rely on your freely given, informed consent. You may withdraw consent at any time without detriment to your account.

The personal data cl99 collects is used for the following specific purposes:

• Account creation and management: Registering your account, maintaining your player profile, enabling login, and managing account settings including deposit limits and responsible gaming preferences.
• Identity verification: Verifying that you are who you say you are, that you are at least 21 years of age, and that you are entitled to use the cl99 platform in accordance with our eligibility requirements.
• Payment processing: Initiating, processing, and reconciling deposits and withdrawals via your chosen payment method. Transaction records are maintained for audit and dispute resolution purposes.
• Fraud and security: Detecting and preventing unauthorised account access, multi-accounting, bonus abuse, money laundering, and any other activity that threatens the integrity of the platform or other players.
• Responsible gaming: Monitoring betting patterns and session behaviour to identify signs of problem gambling and trigger appropriate interventions, in line with our responsible gaming obligations.
• Customer support: Responding to your enquiries, resolving disputes, processing complaints, and providing assistance with account-related issues.
• Platform improvement: Analysing aggregated and anonymised usage data to identify technical issues, improve user experience, and develop new features relevant to Bangladesh players.
• Marketing communications: Sending promotional offers, bonus notifications, and seasonal promotion alerts (BPL, Eid, Pohela Boishakh events, etc.) to players who have opted in to marketing. You may opt out at any time.
• Legal compliance: Meeting our obligations under applicable anti-money laundering laws, responding to lawful requests from regulatory or law enforcement authorities, and maintaining records as required by our operating licence conditions.

cl99 does not sell your personal data. We share your data only with the following categories of third parties, strictly on a need-to-know basis and under contractual data protection obligations:

• Payment processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, City Bank, Islami Bank, Sonali Bank, Visa, and Mastercard receive the minimum personal and financial data necessary to process your transaction. These providers operate under their own privacy policies and data protection frameworks.
• Identity verification providers: Third-party KYC and age verification partners receive your identity document data solely for the purpose of verifying your eligibility to use cl99. Verification results are returned to cl99; raw document images may be stored by the verification provider subject to their retention policy.
• Game studio providers: Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Ezugi, Spribe, and other game providers receive a player identifier (not your full personal profile) to associate game sessions with your cl99 account. Full identity data is not shared with game providers.
• Platform technology providers: Hosting, content delivery, analytics, and customer support platform vendors that power the cl99 technical infrastructure. All such vendors are bound by contractual data processing agreements that prohibit independent use of cl99 player data.
• Regulatory and law enforcement authorities: Where required by applicable law, valid court order, or regulatory direction, cl99 will disclose player data to competent authorities. cl99 will not voluntarily disclose player data to any government body without a valid legal requirement to do so.
• Fraud prevention networks: Where cl99 is a member of a shared fraud intelligence network, anonymised or pseudonymised risk signals may be shared with that network to protect the broader online gambling ecosystem. No personally identifiable information is shared in this context without a specific legal trigger.

cl99 uses cookies and similar tracking technologies to enable essential platform functionality, improve your experience, and collect anonymised analytics data. The cookies we use fall into four categories:

You may control cookie preferences through your browser settings. Please note that disabling functional or analytics cookies may affect certain platform features. Disabling strictly necessary or security cookies will prevent you from using the cl99 platform entirely, as these are required for authentication and transaction security.

cl99 retains personal data only for as long as is necessary for the purpose for which it was collected, or as required by applicable law. The following retention schedule applies:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be associated with any individual player.

As a cl99 player, you hold the following rights with respect to your personal data. All requests are handled by the cl99 privacy team and responded to within 15 business days:

• Right of Access: You may request a copy of all personal data cl99 holds about you. We will provide a structured, machine-readable export upon verified request.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to have it corrected. Contact support with the correct information and supporting evidence where applicable.
• 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, or where we have no legal basis for continued processing. Note that data subject to legal retention obligations (such as transaction records required for AML compliance) cannot be deleted before the end of the mandatory retention period.
• Right to Restriction: You may request that cl99 restrict processing of your data in certain circumstances — for example, while a dispute about accuracy is being resolved.
• Right to Data Portability: You may request your personal data in a portable format (JSON or CSV) for transfer to another service provider, where technically feasible.
• Right to Object: You may object to processing based on legitimate interests, including profiling for responsible gaming purposes. cl99 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw consent at any time by updating your account preferences or contacting support. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

cl99 takes data security seriously and implements a multi-layered approach to protecting player information. Our security measures include:

• SSL/TLS encryption: All data in transit between your device and cl99 servers is encrypted using TLS 1.2 or higher. No unencrypted data is transmitted over public networks.
• Data at rest encryption: Sensitive data stored in cl99 databases — including identity documents and payment method references — is encrypted at the storage layer using AES-256 encryption.
• Access controls: cl99 systems operate on a strict least-privilege model. Employees and contractors can only access the specific player data categories required for their defined role. Access logs are maintained and reviewed regularly.
• Two-factor authentication: Internal cl99 system access requires multi-factor authentication. Players are also encouraged to enable two-factor authentication on their accounts for enhanced personal security.
• Regular security audits: cl99 conducts periodic internal security reviews and engages independent security professionals to conduct penetration testing and vulnerability assessments on a scheduled basis.
• Incident response: cl99 maintains a documented incident response plan. In the event of a confirmed data security incident, affected players will be notified promptly in accordance with the procedure described in Section 1.

While cl99 takes every reasonable precaution to protect your data, no digital system is entirely without risk. You are responsible for maintaining the security of your own account credentials and for using a secure, private device when accessing the cl99 platform.

cl99 operates a strict minimum age requirement of 21 years. The cl99 platform is not directed at, intended for, or designed to attract individuals under the age of 21. We do not knowingly collect personal data from anyone under 21 years of age.

If cl99 discovers or reasonably suspects that personal data has been collected from an individual under 21 — whether through a misrepresentation at registration or any other means — that account will be immediately suspended, all associated data will be flagged for expedited deletion (subject only to any mandatory retention obligations), and the matter may be referred to relevant authorities.

If you are a parent or guardian and believe your child has registered an account with cl99, please contact us immediately at [email protected]. We will investigate and act without delay.

The cl99 platform integrates with several third-party service providers to deliver its full range of features. Each of these providers has its own privacy policy and data protection framework. cl99 conducts due diligence on all third-party partners to ensure adequate data protection standards before integration.

Third-party services integrated into cl99 include game studios (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Ezugi, Spribe, Hacksaw Gaming), payment processors (bKash, Nagad, Rocket, Upay, and the banking partners listed in Section 6), identity verification providers, and platform infrastructure vendors.

cl99 is not responsible for the privacy practices of third-party providers beyond the contractual data processing obligations we place upon them. Players who have direct relationships with these providers — such as existing bKash or Nagad account holders — should review those providers' own privacy policies for information about how their data practices apply to your relationship with them directly.

cl99 operates as an offshore-licensed platform. As a result, your personal data may be transferred to, stored in, or processed in countries outside Bangladesh where our servers, technology infrastructure, or third-party service providers are located. These countries may have data protection laws that differ from those applicable in Bangladesh.

Where such international transfers occur, cl99 takes steps to ensure that your personal data receives an adequate level of protection. These steps include:

• Entering into data processing agreements with all third-party recipients that include contractual obligations requiring appropriate data protection standards equivalent to those described in this policy.
• Conducting transfer impact assessments where required to evaluate whether the protections in the destination country are sufficient for the specific categories of data being transferred.
• Applying technical safeguards such as encryption so that data transferred internationally is protected in transit and at rest, regardless of the legal framework of the destination country.

By using the cl99 platform, you acknowledge and consent to the international transfer of your personal data as described in this section, subject to the protections outlined above.

With your consent, cl99 may send you marketing communications including promotional bonus offers, deposit match notifications, seasonal campaign updates (such as BPL season promotions, Eid special offers, Pohela Boishakh celebrations, and Victory Day events), and new game or feature announcements. These communications may be delivered via SMS to your registered mobile number or email to your registered address.

You may opt out of marketing communications at any time by:

• Updating your communication preferences in your cl99 account settings dashboard.
• Replying STOP to any promotional SMS message sent from cl99.
• Clicking the unsubscribe link included in all cl99 marketing emails.
• Submitting an opt-out request to [email protected] with the subject line "Marketing Opt-Out".

Opting out of marketing communications will not affect your receipt of transactional communications — such as deposit confirmations, withdrawal notifications, account security alerts, and identity verification requests — which are sent regardless of marketing preference as they are necessary for the operation of your account.

cl99 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or the services we offer. All changes will be published on this page with an updated version number and effective date at the top of the document.

Where changes are material — meaning they significantly affect how your personal data is used or your rights as a player — cl99 will provide advance notice of at least 14 days before the new policy takes effect. Notice will be delivered via a prominent notice on the cl99 platform and, where practical, by direct communication to your registered contact details.

Your continued use of the cl99 platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any changes, you should cease using the platform and may request closure of your account before the changes take effect.

We encourage you to review this Privacy Policy periodically to stay informed about how cl99 protects and uses your personal information. The current version number and effective date are always displayed at the top of this page for your reference.

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or have a concern about how cl99 has handled your personal information, please contact our privacy team using the details below.

cl99 takes all privacy complaints seriously. Upon receipt of a complaint, our privacy team will acknowledge your message within 2 business days, investigate the matter thoroughly, and provide a substantive response within 15 business days. If additional time is required due to complexity, we will notify you of the delay and provide an estimated resolution timeline.

If you are not satisfied with cl99's response to your privacy complaint, you may seek further assistance from an independent legal adviser or a relevant consumer protection body in your jurisdiction. cl99 will cooperate fully with any lawful investigation into its data practices.