ll99 Privacy Policy — How We Handle Your Personal Data

1 Introduction

ll99 ("ll99", "we", "us", "our") is committed to protecting the privacy and personal data of every individual who uses the ll99 online betting and casino platform (the "Platform"). This Privacy Policy sets out, in clear and accessible terms, what personal data we collect, why we collect it, how we use it, who we share it with, how long we keep it, and what rights you have in relation to your own data.

This Policy applies to all personal data collected through the ll99 website at ll99.vu, any mobile-optimised interface associated with the Platform, and any communications between you and ll99 via email, live chat, or other support channels. It should be read alongside the ll99 Terms & Conditions and Responsible Gaming policy, both of which are incorporated into the overall agreement between you and ll99.

ll99 is committed to maintaining transparent and honest data practices. We do not use personal data for purposes beyond those described in this Policy, and we do not retain data longer than necessary. If you have any questions about this Policy or our data practices, you are encouraged to contact our support team at any time.

2 Data Controller

For the purposes of this Privacy Policy, ll99 acts as the data controller in respect of the personal data it collects from players and visitors in Bangladesh. As data controller, ll99 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully and fairly.

All data-related queries, access requests, correction requests, and deletion requests should be directed to the ll99 customer support team. Contact details are provided in Section 15 of this Policy.

3 Data We Collect

ll99 collects the following categories of personal data from players and visitors. Data is collected only to the extent necessary to provide the Platform's services and to meet applicable legal and regulatory obligations.

ll99 does not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data, except where identity document photos submitted for KYC purposes may incidentally contain such information. Such data is used solely for identity verification and is not processed for any other purpose.

4 How We Collect Your Data

ll99 collects personal data through the following channels:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technical collection: Data collected automatically when you visit or use the Platform, including IP address, device identifiers, browser type, page views, and session activity, collected via server logs and analytics tools.
• Cookies and similar technologies: Data collected via cookies, session tokens, and local storage on your device. Please refer to Section 8 of this Policy for full details on our use of cookies.
• Third-party payment providers: Transaction confirmation data received from bKash, Nagad, Rocket, Upay, and other supported payment services when you initiate a deposit or withdrawal. ll99 does not receive or store your full payment account credentials from these providers.
• KYC and identity verification: Document images and data submitted by you during the KYC process, including scans or photographs of government-issued identification documents.

5 How We Use Your Data

ll99 uses the personal data we collect for the following purposes. We process your data only where a lawful basis for doing so exists, as described in Section 6 of this Policy.

• Account creation and management: To register your ll99 account, verify your identity and age, and manage your account settings and preferences.
• Transaction processing: To process deposits, withdrawals, and bonus credits accurately and in a timely manner in Bangladeshi Taka (৳ BDT).
• KYC and fraud prevention: To verify your identity, prevent the creation of duplicate accounts, detect and investigate suspicious activity, and protect the integrity of the Platform.
• Customer support: To respond to your support queries, resolve account issues, and handle complaints or disputes.
• Responsible gaming: To monitor player activity for signs of problem gambling behaviour and to apply account-level controls where appropriate in accordance with our Responsible Gaming policy.
• Platform improvement: To analyse aggregated and anonymised usage data to improve the performance, design, and content of the Platform.
• Marketing communications: To send you promotional emails or SMS messages about ll99 offers, bonuses, and new games, but only where you have opted in to receive such communications. You may opt out at any time.
• Legal compliance: To comply with applicable legal and regulatory obligations, including responding to lawful requests from competent authorities.

6 Legal Basis for Processing

ll99 processes your personal data on one or more of the following legal bases, depending on the specific purpose of processing:

• Contractual necessity: Processing required to perform our contract with you — including account registration, transaction processing, and customer support — is carried out because it is necessary to fulfil the Terms & Conditions you agreed to when registering your ll99 account.
• Legitimate interests: Processing for fraud prevention, Platform security, technical troubleshooting, and aggregated analytics is carried out on the basis of ll99's legitimate interests in operating a safe, reliable, and well-functioning platform, provided those interests are not overridden by your rights and freedoms.
• Legal obligation: Processing required to comply with applicable laws and regulations — including KYC obligations, anti-money-laundering requirements, and responses to lawful authority requests — is carried out to fulfil ll99's legal obligations.
• Consent: Processing for direct marketing communications is carried out only where you have given your explicit consent. You may withdraw this consent at any time by updating your marketing preferences in Account settings or by contacting support.

7 Sharing Your Data

ll99 does not sell, rent, or trade your personal data to third parties. We share your personal data only in the limited circumstances described below, and only to the extent necessary for the stated purpose.

• Payment service providers: We share relevant transaction data with bKash, Nagad, Rocket, Upay, and other supported payment providers to facilitate deposits and withdrawals. These providers process your data under their own privacy policies and are responsible for the security of payment data on their platforms.
• Game technology providers: Game studios and software providers (including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Ezugi, and Spribe) may receive technical session data necessary to deliver game content to you. These providers do not receive your full identity or financial data.
• KYC and identity verification services: Where third-party identity verification tools are used to assist with KYC compliance, your identity document data may be shared with such providers in a secure, encrypted format solely for the purpose of verification.
• Legal and regulatory authorities: ll99 may disclose personal data to law enforcement agencies, regulatory bodies, or courts where required to do so by law, or where disclosure is necessary to protect the rights, property, or safety of ll99, its players, or the public.
• Business successors: In the event of a merger, acquisition, or transfer of all or part of ll99's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and the privacy implications before it takes effect.

All third parties with whom ll99 shares personal data are required to handle that data in accordance with applicable data protection standards and are prohibited from using it for any purpose beyond the stated purpose of sharing.

8 Cookies & Tracking

ll99 uses cookies and similar technologies on the Platform to ensure the site functions correctly, to remember your preferences, and to gather aggregated analytics data about how the Platform is used. A cookie is a small text file stored on your device when you visit a website.

ll99 uses the following categories of cookies:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies that keep you logged into your ll99 account during a session. These cookies cannot be disabled without preventing the Platform from working.
• Functional cookies: Used to remember your preferences such as language settings, last-visited game categories, and responsible gaming tool selections. Disabling these may reduce your Platform experience.
• Analytics cookies: Used to collect aggregated, anonymised data about how players navigate and interact with the Platform. This data is used solely to improve Platform performance and content. ll99 does not use analytics data to identify individual users.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and unauthorised use of the Platform. These cookies are part of ll99's security infrastructure and cannot be disabled.

ll99 does not use third-party advertising or retargeting cookies. Your browsing activity on the ll99 Platform is not shared with advertising networks. You may manage cookie preferences through your browser settings, but please note that disabling certain categories of cookies may affect Platform functionality.

9 Data Security

ll99 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the ll99 Platform.
• Encrypted storage of sensitive data, including account passwords (stored as one-way hashes) and identity document files.
• Access controls ensuring that personal data is accessible only to ll99 staff and service providers with a legitimate need to access it in the course of their duties.
• Regular security assessments and monitoring of Platform infrastructure for vulnerabilities and suspicious activity.
• Incident response procedures to detect, investigate, and address data security breaches in a timely manner.

While ll99 takes all reasonable precautions to protect your data, no internet-based platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying ll99 immediately if you suspect any unauthorised access to your account. ll99 will never ask for your password via email, live chat, or any other communication channel.

10 Data Retention

ll99 retains your personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention periods apply:

• Account and identity data: Retained for the lifetime of your ll99 account and for a period of five (5) years following permanent account closure, to satisfy anti-money-laundering and KYC record-keeping obligations.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, in accordance with financial record-keeping requirements.
• Customer support communications: Retained for a period of three (3) years from the date of the last interaction, for quality assurance and dispute resolution purposes.
• Technical and usage data: Aggregated analytics data is retained indefinitely in anonymised form. Raw technical logs (e.g., IP access logs) are retained for up to ninety (90) days for security purposes, then deleted.
• Marketing preference data: Retained until you withdraw consent for marketing communications, at which point your data will be removed from active marketing lists within a reasonable processing period.

Upon expiry of the applicable retention period, personal data is securely deleted or permanently anonymised so that it can no longer be attributed to an identified individual.

11 Your Rights

As a player or visitor whose personal data is held by ll99, you have the following rights in relation to your data. ll99 will respond to all valid data rights requests within a reasonable timeframe and at no charge to you.

• Right of access: You have the right to request a copy of the personal data ll99 holds about you, together with information about how that data is processed.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data ll99 holds about you. You may update certain account details directly through your Account settings.
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, or where you withdraw consent and no other lawful basis for processing exists. Note that ll99 may be required to retain certain data to fulfil legal obligations even following an erasure request.
• Right to restrict processing: You have the right to request that ll99 restricts the processing of your personal data in certain circumstances, such as while a correction request is being assessed.
• Right to data portability: Where processing is based on your consent or on contractual necessity, you have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to withdraw consent: Where ll99 processes your data on the basis of consent (for example, for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to object: You have the right to object to processing of your personal data where that processing is based on ll99's legitimate interests, including profiling for responsible gaming monitoring purposes.

To exercise any of these rights, please contact our support team as described in Section 15. ll99 may need to verify your identity before processing a data rights request to ensure we do not disclose data to an unauthorised third party.

12 Children & Minors

The ll99 Platform is strictly intended for adults aged 21 years and above. ll99 does not knowingly collect personal data from individuals under the age of 21. If ll99 becomes aware that personal data has been collected from a person under 21, that data will be deleted immediately and the associated account will be closed without compensation.

If you are a parent or guardian and believe that a minor in your care has registered an account or provided personal data to ll99, please contact our support team immediately so that we can investigate and take appropriate action. ll99 takes underage access to its Platform very seriously and cooperates fully with guardians and relevant authorities in addressing such cases.

13 Third-Party Links

The ll99 Platform may, from time to time, contain references to third-party services such as payment providers (bKash, Nagad, Rocket) or game studios. Where such services are accessed through separate websites or applications operated by third parties, those websites are governed by their own privacy policies. ll99 has no control over the data practices of third-party websites and accepts no responsibility or liability for their privacy practices.

You are encouraged to review the privacy policies of any third-party service you access in connection with your use of the ll99 Platform, particularly your chosen payment provider's policy, before submitting personal or financial information to them.

14 Policy Changes

ll99 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the services we provide. When material changes are made to this Policy, ll99 will notify registered players via email or in-platform notification prior to the changes taking effect. The updated Policy will be published at ll99.vu/privacy-policy with the revised "Last Updated" date at the top.

Your continued use of the ll99 Platform following notification of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the revised Policy, you should discontinue use of the Platform and contact our support team to arrange account closure and request deletion of your personal data in accordance with Section 11.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data ll99 holds about you, please contact our customer support team. Our support team is available 24 hours a day, 7 days a week, in Bangladesh Standard Time (BST, UTC+6).

Support contact: [email protected]

Please include your registered account username, a clear description of your query or request, and — for data rights requests — a form of identity verification so that we can process your request securely and efficiently.