ha99 Privacy Policy

1 Data We Collect

When you register an account, use the ha99 platform, or interact with our customer support team, ha99 collects personal data in several categories. We only collect information that is necessary for a specific, legitimate purpose — we do not collect data speculatively or beyond what is required.

Registration Data

When you create a ha99 account, we collect the following information directly from you:

• Full legal name — as it appears on your National Identity Card (NID) or passport
• Date of birth — for age verification purposes (18+ requirement)
• Email address — for account communications and security notifications
• Mobile phone number — for account verification and two-factor authentication
• Residential address — for identity verification and regulatory compliance
• Username and encrypted password — for account access

Identity Verification (KYC) Data

As part of our Know Your Customer (KYC) process, we may collect and store copies of the following documents:

• National Identity Card (NID) — front and back
• Valid passport (photo and data page)
• Proof of address (utility bill, bank statement dated within 3 months)
• Selfie photograph with identity document (where requested)
• Proof of payment method ownership (e.g., bKash account screenshot, bank statement header)

Financial Transaction Data

ha99 records all deposit and withdrawal transactions associated with your account. This includes transaction amounts in BDT (৳), timestamps, payment method type (bKash, Nagad, Rocket, Upay, bank transfer, or card), transaction reference numbers, and the outcome status of each transaction. We do not store full card numbers, bKash PINs, or mobile banking passwords — these are handled exclusively by the respective payment providers.

Gaming Activity Data

We record your gaming history on ha99, including game sessions, wager amounts, game outcomes, bonus claims, and wagering progress. This data is used for account integrity, responsible gaming monitoring, dispute resolution, and improving platform performance.

Technical & Device Data

When you access ha99 via a browser or mobile device, we automatically collect certain technical data, including:

• IP address and approximate geographic location (city/district level)
• Device type, operating system, and browser version
• Session duration, page views, and navigation path on the ha99 platform
• Device fingerprint data used to detect duplicate accounts and prevent fraud
• Cookies and similar tracking data (see Section 4)

Communications Data

If you contact ha99's support team via email or live chat, we retain a record of your communications, including the content of messages and any attachments you provide. This data is used to resolve your query and to maintain a history of support interactions for quality assurance.

2 How We Use Your Data

ha99 processes your personal data only for clearly defined, lawful purposes. The table below summarises our primary data processing activities and the legal basis for each.

Marketing Communications

ha99 may send you promotional emails, SMS messages, or in-platform notifications about bonuses, new games, and seasonal offers — but only if you have explicitly opted in to receive marketing communications during registration or through your account settings. You may withdraw your marketing consent at any time by updating your communication preferences in your account dashboard or by contacting [email protected].

3 Data Sharing & Third Parties

ha99 does not sell, rent, or trade your personal data to any third party. We share your data only in the limited circumstances described below, and only to the extent necessary for the stated purpose.

Game Suppliers

ha99's casino and sports betting platform is powered by third-party game studios and data providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi. These suppliers may receive anonymised or pseudonymised session data to support game delivery, RTP auditing, and technical troubleshooting. They do not receive your full name, contact details, or payment information unless specifically required for a licensed compliance audit.

Payment Processors

To process deposits and withdrawals, ha99 shares the minimum necessary financial data with your chosen payment provider — for example, your bKash or Nagad registered mobile number, or your bank account details. These providers operate under their own privacy policies and regulatory frameworks. ha99 is not responsible for the data practices of independent payment processors, and we encourage you to review their privacy policies before initiating a transaction.

Identity Verification Services

ha99 may use third-party KYC and identity verification service providers to assist with document validation and fraud screening. These providers process your identity documents under strict confidentiality agreements and are prohibited from using your data for any purpose other than the verification service commissioned by ha99.

Legal & Regulatory Disclosure

ha99 may disclose your personal data to law enforcement agencies, regulatory authorities, or courts of competent jurisdiction when required to do so by a valid legal order, warrant, or regulatory directive. In all such cases, ha99 will disclose only the minimum information required to satisfy the legal obligation, and will notify you of the disclosure where legally permissible to do so.

Business Transfers

In the event that ha99's platform or business assets are acquired, merged, or transferred to another entity, your personal data may form part of the transferred assets. In such circumstances, ha99 will notify you via your registered email address prior to your data being transferred and becoming subject to a different privacy policy. You will retain the right to request deletion of your data at that time.

4 Cookies & Tracking Technologies

ha99 uses cookies and similar technologies (including local storage, session storage, and pixel tags) to operate the platform, keep you logged in securely, personalise your experience, and analyse how players interact with our site. By continuing to use ha99, you consent to our use of cookies as described in this section.

Types of Cookies We Use

Managing Cookies

You may configure your browser to block or delete cookies at any time. However, please be aware that disabling strictly necessary cookies will prevent ha99 from functioning correctly — you will not be able to log in, place bets, or process transactions if these cookies are blocked. Functional and analytics cookies can be disabled without affecting core platform access. To adjust cookie settings, refer to your browser's privacy or settings menu.

5 Data Retention

ha99 retains your personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following retention schedule applies:

Once the applicable retention period has expired, ha99 will securely delete or irreversibly anonymise your personal data. Anonymised aggregate data (from which you cannot be individually identified) may be retained indefinitely for statistical and platform improvement purposes.

Account Deletion Requests

If you request deletion of your ha99 account, we will remove or anonymise your personal data within 30 days of the request, subject to our legal obligations to retain certain categories of data (particularly financial and KYC records) for the minimum periods required by applicable law. We will inform you which data categories we are legally required to retain and for how long at the time your deletion request is processed.

6 Your Privacy Rights

ha99 respects your rights over your own personal data. As a player on the ha99 platform, you hold the following rights with respect to the personal data we hold about you:

• Right of Access: You may request a copy of all personal data ha99 holds about you at any time. We will provide this within 30 days of a verified request.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it without undue delay.
• Right to Erasure: You may request that ha99 delete your personal data, subject to our legal retention obligations. See the Data Retention section for the categories of data we are required to retain beyond account closure.
• Right to Restriction: You may ask ha99 to restrict processing of your data in certain circumstances — for example, while a dispute about data accuracy is being resolved.
• Right to Data Portability: You may request that ha99 provide your personal data in a structured, commonly used, machine-readable format so that you can transfer it to another service provider.
• Right to Object: You may object to ha99 processing your personal data on the grounds of legitimate interest, including for direct marketing purposes. Where your objection relates to marketing, we will stop processing immediately.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing that occurred before withdrawal.

How to Exercise Your Rights

To exercise any of the rights listed above, please send a written request to our support team at [email protected] with the subject line "Privacy Rights Request". Please include your full name and registered email address so that we can verify your identity before processing the request. We will acknowledge your request within 5 business days and aim to fulfil it within 30 calendar days. For complex or multiple requests, this period may be extended by a further 30 days, of which we will notify you.

7 Data Security

ha99 takes the security of your personal data seriously and has implemented a range of technical and organisational measures designed to protect your data against unauthorised access, loss, alteration, or disclosure.

Technical Security Measures

• SSL/TLS Encryption: All data transmitted between your browser or device and ha99's servers is encrypted using industry-standard TLS 1.2 or higher. Look for the padlock icon in your browser address bar when using ha99.
• Password Hashing: Account passwords are never stored in plain text. They are hashed using a strong, salted cryptographic algorithm before storage.
• Two-Factor Authentication (2FA): ha99 supports 2FA via SMS OTP for account login, providing an additional layer of protection against unauthorised access.
• Data Segmentation: Player personal data, financial records, and gaming activity data are stored in segmented systems with strict access controls, ensuring that no single data breach can expose all categories of player data simultaneously.
• Regular Security Audits: ha99's platform undergoes periodic security assessments and penetration testing to identify and remediate vulnerabilities proactively.

Organisational Security Measures

Access to player personal data within ha99 is restricted on a strict need-to-know basis. Only staff with a legitimate operational requirement — such as the KYC team, fraud prevention team, or customer support team — are permitted to access player data, and only within the scope of their specific role. All staff with access to personal data are trained in data protection obligations and are bound by confidentiality agreements.

Data Breach Response

In the unlikely event of a data security breach that affects your personal data, ha99 will notify affected players via their registered email address without undue delay after becoming aware of the breach. The notification will describe the nature of the breach, the categories of data affected, the likely consequences, and the steps ha99 is taking to address the breach and mitigate its effects. ha99 will also notify relevant authorities as required by applicable law.

8 Contact & Policy Updates

Contacting ha99 About Privacy

If you have any questions, concerns, or complaints about this Privacy Policy or about how ha99 handles your personal data, please contact our privacy team directly:

• Email: [email protected] (subject line: "Privacy Enquiry")
• Response time: We aim to respond to all privacy enquiries within 5 business days (Bangladesh Standard Time, UTC+6).

If you are not satisfied with ha99's response to a privacy complaint, you may wish to escalate the matter to the relevant data protection authority in your jurisdiction. ha99 will cooperate fully with any such authority in the handling of your complaint.

Changes to This Privacy Policy

ha99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or platform operations. When we make material changes to this policy, we will:

• Update the "Last updated" date at the top of this page
• Publish the revised policy at ha99.app/privacy-policy
• Send a notification to your registered email address if the changes are significant and affect how we process your personal data

Your continued use of ha99 following any update to this Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the updated policy, you should stop using the platform and may request account closure by contacting [email protected].