fo99 Privacy Policy — How We Protect Your Personal Data

1. Introduction

fo99 ("we", "us", "our") operates the online casino and sports betting platform accessible at fo99.io, serving registered players across Bangladesh. This Privacy Policy ("Policy") describes how fo99 collects, processes, stores, shares, and protects personal data in connection with the provision of our services.

This Policy applies to all data subjects whose personal information is processed by fo99, including registered players, prospective players who interact with the fo99 website without completing registration, and individuals who contact our support team. This Policy should be read alongside the fo99 Terms & Conditions and Responsible Gaming Policy.

fo99 takes its data protection obligations seriously. We have implemented technical and organisational measures to ensure that personal data is processed lawfully, fairly, and transparently in accordance with applicable data protection principles.

2. Data Controller

fo99 acts as the data controller in respect of personal data collected through the fo99 platform. As data controller, fo99 determines the purposes and means of processing personal data. If you have any questions or concerns regarding how fo99 processes your personal data, you may contact us at [email protected].

3. Personal Data We Collect

fo99 collects the following categories of personal data in connection with the operation of our platform:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification details (such as National ID or passport number) collected during account registration and Know Your Customer (KYC) verification.
• Contact Data: Email address, mobile phone number, and residential address. These are collected during registration and may be used for account communications, security alerts, and support correspondence.
• Financial Data: Mobile wallet account identifiers (such as bKash and Nagad account numbers), bank account details, transaction amounts, deposit and withdrawal history, and payment method verification documentation.
• Account Data: Username, encrypted password, account preferences, betting history, game session history, bonus usage, wagering records, and responsible gaming tool settings.
• Technical Data: IP address, browser type and version, device type, operating system, screen resolution, session duration, pages visited, referring URLs, and other standard web analytics data collected automatically when you access fo99.
• Communications Data: Records of correspondence between you and fo99 support, including live chat transcripts, email exchanges, and any supporting documentation submitted in connection with a support query or complaint.
• Verification Documents: Copies of identity documents, proof of address documents, and proof of payment method ownership submitted during the KYC verification process.

4. How We Collect Your Data

fo99 collects personal data through the following means:

• Direct Collection: Information you provide when completing the fo99 registration form, submitting KYC documents, making a deposit or withdrawal, contacting our support team, or responding to a survey or promotion.
• Automated Collection: Technical data is collected automatically via cookies, web beacons, server logs, and similar tracking technologies when you access and interact with the fo99 website. See Section 10 for more details on cookies.
• Third-Party Sources: We may receive data about you from third-party identity verification providers, fraud detection services, and payment processors where this is necessary to verify your identity, process payments, or prevent financial crime.

5. How We Use Your Personal Data

fo99 uses the personal data we collect for the following purposes:

• Account Management: To create and maintain your fo99 player account, verify your identity during registration and at subsequent intervals, and manage your account settings and preferences.
• Service Delivery: To provide access to fo99's casino games, sports betting markets, live dealer tables, and all other products and features available on the platform.
• Payment Processing: To process deposits and withdrawals via bKash, Nagad, Rocket, Upay, and other supported payment methods, and to verify the ownership of payment instruments used on your account.
• Legal Compliance: To fulfil our obligations under applicable anti-money laundering (AML) regulations, Know Your Customer (KYC) requirements, and any other legal or regulatory obligations to which fo99 is subject.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorised account access, collusion, bonus abuse, and other forms of misconduct on the fo99 platform.
• Responsible Gaming: To monitor player behaviour patterns that may indicate problem gambling, to implement responsible gaming tools requested by players, and to enforce self-exclusion restrictions where applicable.
• Customer Support: To respond to your queries, complaints, and support requests, and to maintain records of correspondence for quality assurance and dispute resolution purposes.
• Marketing Communications: Where you have provided your consent, to send you promotional offers, bonus notifications, tournament announcements, and other marketing communications by email or SMS. You may withdraw your marketing consent at any time by contacting [email protected].
• Platform Improvement: To analyse aggregated usage data, identify technical issues, improve the performance and user experience of the fo99 platform, and develop new features and services.

6. Legal Basis for Processing

fo99 processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and fo99 as set out in the Terms & Conditions. This includes account creation, payment processing, and the delivery of gaming services.
• Legal Obligation: Processing is necessary to comply with legal and regulatory obligations applicable to fo99, including AML obligations, KYC requirements, and responsible gaming regulations.
• Legitimate Interests: Processing is necessary for the legitimate interests of fo99, including fraud prevention, platform security, improving our services, and maintaining the integrity of our gaming environment, provided that these interests are not overridden by your data protection rights.
• Consent: Where fo99 relies on your consent as the legal basis for processing — for example, in connection with marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

7. Sharing Your Personal Data

fo99 does not sell, rent, or trade your personal data to any third party. We may share your personal data with the following categories of recipients where necessary and on a strictly need-to-know basis:

• Payment Processors: Mobile wallet operators (bKash, Nagad, Rocket, Upay), banks (Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank), and international card networks (Visa, Mastercard) to process your transactions.
• Identity Verification Providers: Third-party KYC and identity verification service providers engaged to verify the authenticity of documents and confirm your identity as part of our compliance obligations.
• Fraud Prevention Services: Specialist third-party providers who assist fo99 in detecting and preventing fraudulent activity, unauthorised access, and financial crime on the platform.
• Game Software Providers: Game studios and content providers (including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi) may receive limited technical data necessary to deliver games and resolve technical disputes, but they do not receive personally identifiable information beyond what is required for this purpose.
• Legal and Regulatory Authorities: We may be required to disclose your personal data to law enforcement agencies, regulators, or courts where we are legally compelled to do so, or where disclosure is necessary to protect the rights, property, or safety of fo99, our players, or the public.
• Professional Advisors: Solicitors, accountants, and auditors engaged by fo99 in connection with the operation of our business, subject to confidentiality obligations.

When fo99 shares personal data with third-party service providers, we require those providers to implement appropriate technical and contractual safeguards to protect your data and to process it only in accordance with our instructions and applicable data protection law.

8. Data Retention

fo99 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, to maintain your active player account, and to comply with our legal, regulatory, and contractual obligations. Specific retention periods are as follows:

• Active Account Data: Retained for the full duration of your fo99 account and for a minimum of five years following account closure, in accordance with standard AML record-keeping requirements.
• Transaction Records: Deposit and withdrawal records are retained for a minimum of five years from the date of each transaction.
• KYC Documents: Identity and address verification documents are retained for a minimum of five years following the completion of the KYC process or the closure of your account, whichever is later.
• Support Correspondence: Records of customer support interactions are retained for a minimum of three years from the date of each interaction.
• Technical and Analytics Data: Aggregated and anonymised technical data may be retained indefinitely for platform analytics and improvement purposes. Identifiable technical data such as IP address logs is retained for a maximum of 12 months.

When personal data is no longer required, fo99 will securely delete or anonymise it in a manner that prevents reconstruction of the original data.

9. Security Measures

fo99 implements a layered set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. These measures include:

• Encryption in Transit: All data transmitted between your device and the fo99 platform is encrypted using industry-standard 256-bit SSL/TLS protocols.
• Encryption at Rest: Sensitive personal data and financial records stored on fo99 servers are encrypted at rest using modern encryption standards.
• Access Controls: Access to personal data within fo99 is restricted to authorised personnel who have a legitimate need to access it in connection with their job responsibilities. All staff with access to personal data are subject to confidentiality obligations.
• Password Security: Player account passwords are stored using one-way cryptographic hashing functions. fo99 never stores passwords in plain text and cannot retrieve your password — only reset it.
• Monitoring and Intrusion Detection: fo99 employs automated monitoring tools to detect suspicious access patterns, attempted intrusions, and anomalous account activity in real time.
• Regular Security Reviews: fo99 conducts periodic security assessments and vulnerability testing to identify and remediate potential weaknesses in our systems and infrastructure.

10. Cookies and Tracking Technologies

fo99 uses cookies and similar tracking technologies to operate the platform, remember your preferences, analyse usage patterns, and deliver a personalised experience. The categories of cookies used by fo99 are as follows:

• Strictly Necessary Cookies: These cookies are essential for the fo99 platform to function and cannot be disabled. They include session management cookies, login authentication tokens, and security cookies that protect against cross-site request forgery.
• Analytics Cookies: We use privacy-respecting analytics tools to collect aggregated data about how players navigate the fo99 website, which pages are most visited, and where users encounter difficulties. This data helps us improve the platform experience.
• Functional Cookies: These cookies remember your preferences such as language settings, display preferences, and responsible gaming tool configurations, so you do not need to reconfigure them on each visit.
• Marketing Cookies: Where you have provided consent, fo99 may use cookies to personalise promotional content and bonus offers presented to you based on your activity on the platform. These cookies do not track your browsing activity on other websites.

You may control your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may impair the functionality of the fo99 platform. For detailed information on how to manage cookies in your specific browser, please refer to your browser's help documentation.

11. Your Data Protection Rights

As a data subject whose personal information is processed by fo99, you hold the following rights in respect of your personal data:

• Right of Access: You have the right to request a copy of the personal data fo99 holds about you, along with information about how it is processed. fo99 will respond to access requests within a reasonable timeframe.
• Right to Rectification: If any personal data fo99 holds about you is inaccurate or incomplete, you have the right to request that it be corrected or updated. You may update many of your account details directly through your fo99 account settings.
• Right to Erasure: In certain circumstances, you have the right to request that fo99 delete your personal data. This right is subject to overriding legal obligations — for example, fo99 is required to retain AML-related records for a minimum period regardless of erasure requests.
• Right to Restriction of Processing: You have the right to request that fo99 restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to its processing.
• 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, machine-readable format.
• Right to Object: You have the right to object to the processing of your personal data where fo99 relies on legitimate interests as the legal basis for processing. You also have an unconditional right to object to the processing of your data for direct marketing purposes.
• Right to Withdraw Consent: Where fo99 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 prior processing.

To exercise any of the rights listed above, please contact fo99 at [email protected] with a clear description of your request. fo99 may need to verify your identity before fulfilling your request. We will acknowledge your request promptly and aim to provide a substantive response within 30 calendar days.

12. Minors and Under-21 Players

The fo99 platform is strictly intended for adults aged 21 and above. fo99 does not knowingly collect personal data from individuals under the age of 21. If we become aware that a player account has been registered by someone under the minimum age, we will immediately suspend the account, delete all associated personal data to the extent permitted by law, and handle any associated funds in accordance with our underage player policy.

If you are a parent or guardian and believe that a minor has registered a fo99 account using your contact details or payment methods, please contact us immediately at [email protected] so that we can investigate and take appropriate action.

13. Changes to This Privacy Policy

fo99 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or the features and services available on the platform. The date of the most recent revision is displayed at the top of this document.

Where we make material changes to this Policy that significantly affect how we process your personal data, we will notify registered players via the email address associated with their fo99 account. Your continued use of the fo99 platform after the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not accept the revised Policy, please discontinue use of fo99 and contact us to arrange account closure.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way fo99 processes your personal data, please contact our data protection team through the following channel:

• Email: [email protected] (plain text — not a clickable link)
• Response Hours: 24 hours a day, 7 days a week
• Response Time: Acknowledgement within 48 hours; substantive response within 30 calendar days

fo99 is committed to resolving all data protection queries and complaints promptly and transparently. If you are not satisfied with our response, you may have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction.