tr99 Privacy Policy

This Privacy Policy ("Policy") describes how tr99 ("tr99", "we", "us", "our") collects, uses, shares, stores, and protects personal data relating to players and visitors ("you", "your") who access or use the tr99 platform at tr99.vu. This Policy forms part of the tr99 Terms & Conditions and should be read alongside the Responsible Gaming Policy. By registering an account with tr99 or continuing to use the platform, you acknowledge that you have read and understood this Policy and you consent to the processing of your personal data as described herein.

This Policy applies to all personal data processed by tr99 in connection with: (a) the creation and management of player accounts; (b) the provision of online casino games, sports betting, crash games, card games, and all other services available on the platform; (c) the processing of financial transactions including deposits and withdrawals via bKash, Nagad, Rocket, Upay, and bank transfer; (d) customer support communications; (e) the administration of promotions, bonuses, and loyalty programmes; and (f) compliance with legal and regulatory obligations.

tr99 takes data privacy seriously and is committed to handling your personal data with transparency, care, and respect. If you have questions about this Policy or wish to exercise any of your data rights, please contact us at [email protected]. We aim to respond to all privacy-related enquiries and formal rights requests within 30 calendar days of receipt.

tr99 processes personal data only for specific, legitimate purposes. We do not use your data for any purpose that is incompatible with the original purpose for which it was collected without first obtaining your consent or establishing a new legal basis for doing so. The purposes for which we process your personal data include:

• Account creation and management: processing your registration, verifying your identity and age (KYC), maintaining your account profile, and providing access to the platform.
• Transaction processing: handling deposits and withdrawals via approved payment methods including bKash, Nagad, Rocket, and bank transfer; detecting and preventing payment fraud.
• Platform operation and improvement: delivering games, sports betting markets, and platform features; analysing usage patterns to improve performance, fix bugs, and develop new features.
• Responsible gaming monitoring: identifying patterns of play that may indicate problem gambling; delivering responsible gaming interventions such as deposit limit reminders and self-exclusion processing.
• Fraud prevention and security: detecting unauthorised access, bot activity, multi-accounting, bonus abuse, and money laundering; protecting the integrity of the platform and the security of all player accounts.
• Legal and regulatory compliance: fulfilling obligations under applicable anti-money-laundering law, age verification requirements, and any other legal obligations that apply to tr99's operations.
• Customer support: responding to your enquiries, resolving disputes, processing complaints, and maintaining records of support interactions for quality assurance purposes.

Where tr99 relies on your consent to process data for a specific purpose (for example, sending you promotional emails about bonuses and new game launches), you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing that occurred before the withdrawal. To withdraw consent for marketing communications or to update your communication preferences, contact [email protected] or use the opt-out mechanism in any marketing message you receive from tr99.

tr99 processes personal data under one or more of the following legal bases, depending on the category of data and the purpose of processing:

• Contract performance: processing that is necessary to provide the services you have requested when creating an account, placing a bet, or requesting a withdrawal. Without this processing, tr99 cannot fulfil its contractual obligations to you.
• Legal obligation: processing required to comply with applicable laws, including age verification, anti-money-laundering obligations, and the retention of financial transaction records for the legally mandated period.
• Legitimate interests: processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement where tr99's legitimate business interests are not overridden by your privacy rights. tr99 conducts a balancing assessment before relying on this basis.
• Consent: processing for optional purposes such as sending promotional communications, personalised game recommendations, and non-essential analytics cookies. You may withdraw consent for these purposes at any time without affecting the lawfulness of prior processing.

The categories of third parties with whom tr99 may share your personal data, and the basis for doing so, are as follows:

• Payment processors: bKash, Nagad, Rocket, Upay, and banking partners receive the minimum transaction data necessary to process deposits and withdrawals. These partners are contractually bound to process payment data only for the purpose of completing the transaction and are prohibited from using the data for any other purpose.
• Game providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and other certified game studios receive session and gameplay data necessary to deliver the game experience and to detect cheating or technical issues within their game environment. Game providers do not receive your financial data or KYC documents.
• KYC and identity verification partners: specialist third-party verification services may receive copies of identity documents and biographic data for the purpose of performing age and identity checks. These partners are contractually bound by strict data confidentiality obligations and are prohibited from retaining verification documents beyond the period required to complete the check.
• Analytics and platform improvement services: anonymised or pseudonymised technical and gameplay data may be shared with analytics service providers to help tr99 understand platform usage patterns and improve the user experience. No personally identifiable data is shared for analytics purposes.
• Law enforcement and regulatory authorities: where tr99 is legally required to disclose personal data to a government body, law enforcement agency, court, or regulatory authority, tr99 will comply with the applicable legal obligation. tr99 will, where permitted by law, notify the affected player of such a disclosure.

All third-party data processors engaged by tr99 are required to enter into a data processing agreement that mandates compliance with applicable data protection law, restricts the processor to processing data only on tr99's documented instructions, and requires appropriate technical and organisational security measures. tr99 conducts periodic reviews of its third-party data processors to ensure ongoing compliance.

tr99 processes payment data — including mobile wallet identifiers (bKash, Nagad, Rocket, Upay), bank account references, and transaction records — solely for the purpose of processing player deposits and withdrawals and for complying with anti-money-laundering obligations. tr99 does not store full payment credentials. Where payment data is transmitted between your device and the tr99 platform, it is protected by 256-bit SSL encryption. Payment data is accessible only to tr99's finance team and authorised payment processing partners, under strict need-to-know access controls.

Financial transaction records are retained for a minimum of 5 years from the date of the transaction, in accordance with anti-money-laundering record-keeping requirements. This retention period applies regardless of whether your account remains active. At the end of the retention period, financial transaction records are securely deleted. You may request a statement of your transaction history at any time by contacting [email protected].

tr99 uses cookies and similar tracking technologies on the platform. Cookies are small text files stored on your device that help the platform function correctly and allow tr99 to understand how the platform is being used. tr99 uses the following categories of cookies:

• Essential cookies: strictly necessary for the platform to function. These include session authentication cookies (to keep you logged in), security tokens (to protect against cross-site request forgery), and load-balancing cookies. Essential cookies cannot be disabled without preventing the platform from working correctly.
• Functional cookies: used to remember your preferences such as language settings, responsible gaming limit preferences, and game display settings. These cookies improve your experience but are not essential for basic platform operation.
• Analytics cookies: used to collect anonymised information about how visitors use the platform — including which pages are visited most frequently, session durations, and navigation paths. This data is used to improve the platform's design and performance. Analytics cookies do not identify you personally.
• Security and fraud detection cookies: used to identify and block suspicious activity including bot traffic, coordinated attacks, and account takeover attempts. These cookies are essential for maintaining platform integrity and protecting player accounts.

You can manage cookie preferences for non-essential cookies through your browser settings. Most modern browsers allow you to block all cookies, accept only certain categories of cookies, or delete cookies that have already been set. Please note that blocking essential cookies will impair the functionality of the tr99 platform and may prevent you from logging in or making transactions. For a full list of cookies used by tr99 and their individual retention periods, contact [email protected].

tr99 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 periods apply:

• Account and identity data: retained for the duration of your account and for 5 years following account closure, in accordance with anti-money-laundering record-keeping obligations. After this period, account and identity data is securely deleted or anonymised.
• Financial transaction records: retained for a minimum of 5 years from the date of the transaction in accordance with legal record-keeping requirements. Transaction records may be retained for longer where they are the subject of an active dispute or legal proceeding.
• Customer support communications: retained for 3 years following the resolution of the relevant support interaction, for dispute resolution and quality assurance purposes. After this period, support communication records are securely deleted.

Where you request deletion of your personal data before the end of the applicable retention period, tr99 will assess the request against its legal obligations. Where deletion is not possible because the data is required for legal compliance, tr99 will restrict processing of your data to the minimum necessary for compliance purposes and will delete the data as soon as the retention obligation is satisfied.

tr99 will not charge a fee for processing any data rights request unless the request is manifestly unfounded or excessive, in which case a reasonable administrative fee may be applied. tr99 may ask you to verify your identity before processing a data rights request to ensure that personal data is not disclosed to an unauthorised person. If you believe that tr99 has failed to handle your personal data in accordance with this Policy, you have the right to raise a complaint by contacting [email protected].

tr99 implements a range of technical and organisational security measures to protect personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data in transit between your device and the tr99 platform, ensuring that your personal and financial data cannot be intercepted by third parties during transmission.
• Encrypted storage of all sensitive personal data at rest, including KYC documents, payment references, and account credentials. Passwords are stored using industry-standard one-way hashing algorithms and are never stored in plain text.
• Role-based access controls that limit access to personal data to only those tr99 staff and contractors who have a documented operational need to access that data. Access logs are maintained and reviewed periodically.
• Regular security assessments, penetration testing, and vulnerability scanning to identify and remediate security weaknesses in the platform infrastructure. Critical security patches are applied on a priority basis with minimal delay.

Despite these measures, no internet-based platform can guarantee absolute security. tr99 cannot guarantee that its security measures will always be sufficient to prevent a determined attacker from gaining unauthorised access. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, tr99 will notify you as soon as practicable after becoming aware of the breach, in accordance with applicable law. If you suspect that your tr99 account has been compromised, contact [email protected] immediately.

If you believe that a person under the age of 21 has registered an account with tr99, or that tr99 holds personal data relating to a minor, please contact [email protected] immediately. tr99 takes this responsibility seriously and will act promptly to investigate and resolve any such report. Parents and guardians who are concerned about underage access to online gambling platforms are encouraged to use parental control software and to discuss responsible internet use with young people in their care.

tr99 may send you promotional communications about bonuses, new game launches, seasonal promotions (including Eid, Pohela Boishakh, and BPL and IPL cricket season offers), and platform updates. tr99 will send marketing communications only where you have given your express consent to receive them. You may give consent to receive marketing communications during the account registration process or at any subsequent point via your account settings page.

You may withdraw consent to receive marketing communications at any time by: (a) clicking the unsubscribe link in any marketing email or SMS you receive from tr99; (b) updating your communication preferences in your tr99 account settings page; or (c) contacting [email protected] with a request to be removed from all marketing lists. Withdrawal of marketing consent will not affect the delivery of essential account communications such as transaction confirmations, account security alerts, and KYC verification requests, which tr99 is required to send regardless of marketing preferences.

tr99 operates primarily for the Bangladesh market and processes the majority of personal data within its primary operating infrastructure. However, some of tr99's service providers — including certain game studios and technical infrastructure providers — may process data in jurisdictions outside Bangladesh. Where personal data is transferred to a jurisdiction that does not provide an equivalent level of data protection to that applicable in Bangladesh, tr99 will implement appropriate safeguards to protect that data, which may include contractual data protection clauses, data processing agreements, or other legally recognised transfer mechanisms.

Where you request information about the safeguards in place for a specific international data transfer, tr99 will provide that information within 30 days of receiving your request. Contact [email protected] to make such a request.

tr99 reviews this Privacy Policy periodically and may update it to reflect changes in the way tr99 processes personal data, changes in applicable law, or improvements to the platform. Where a material change is made to this Policy, tr99 will endeavour to notify registered players by posting a notice on the platform homepage or by sending a notification to the mobile number associated with your account, at least 7 days before the change takes effect.

The "Last Updated" date at the top of this page reflects the date on which the current version of this Policy was published. Your continued use of the tr99 platform after any update to this Policy constitutes your acceptance of the updated Policy. If you do not agree with any update, you should stop using the platform and may request account closure in accordance with the Terms & Conditions.

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, want to report a concern about how tr99 is handling your personal data, or wish to withdraw consent for any form of data processing, please contact the tr99 privacy team. All privacy queries and data rights requests are handled confidentially and with priority.

Email: [email protected]

We aim to respond to all privacy-related enquiries within 30 calendar days of receipt. For complex requests that require additional time, we will acknowledge your request within 5 business days and provide a revised response timeline.