Zoya 99 Privacy Policy

1. Who We Are

Zoya 99 is an online gaming platform operated for players in Bangladesh. When this Privacy Policy refers to "Zoya 99", "we", "us" or "our", it means the entity responsible for operating the platform and processing your personal data.

Zoya 99 acts as the data controller for all personal information collected through the platform. This means we determine the purposes and means of processing your data. If you have any questions about how your data is handled, you can reach us at [email protected].

2. Data We Collect

Zoya 99 collects personal data in several categories depending on how you interact with the platform. Here is a clear breakdown of what we collect and why:

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs or biometric data unless specifically required by law and with your explicit consent.

3. How We Collect Your Data

Zoya 99 collects your personal data through the following channels:

• Direct registration: When you create a Zoya 99 account, you provide your name, date of birth, email address and mobile number directly.
• Payment transactions: When you make a deposit or withdrawal, your payment provider shares transaction reference data with us to confirm the transfer.
• Platform usage: As you use the Zoya 99 website or app, we automatically collect technical and usage data through cookies and server logs.
• KYC verification: When you submit identity documents for verification, we collect the information contained in those documents.
• Support interactions: When you contact our support team via live chat or email, we collect the content of those communications.
• Third-party sources: In some cases we may receive data from fraud prevention agencies or identity verification services to help us confirm your identity and protect your account.

4. Why We Use Your Data

Zoya 99 uses your personal data for the following purposes. We only use your data for the reason it was collected — we do not repurpose data without informing you first.

• To create and manage your Zoya 99 account.
• To process deposits and withdrawals via bKash, Nagad and Rocket.
• To verify your identity and age in compliance with our licensing obligations.
• To detect and prevent fraud, money laundering and other prohibited activity.
• To monitor your gaming activity for responsible gaming purposes and intervene if we identify signs of problem gambling.
• To send you account-related communications such as transaction confirmations, security alerts and policy updates.
• To respond to your support queries and resolve disputes.
• To improve the Zoya 99 platform through anonymised analytics and user feedback.
• To comply with applicable laws and regulatory requirements.

5. Legal Basis for Processing

Zoya 99 processes your personal data on the following legal grounds:

• Contract performance: Processing your data is necessary to provide the Zoya 99 service you have signed up for, including account management and payment processing.
• Legal obligation: We are required by law to collect and retain certain data for anti-money laundering compliance, age verification and regulatory reporting.
• Legitimate interests: We process technical and usage data to protect the security of the platform, prevent fraud and improve our service — provided these interests do not override your rights.
• Consent: Where we rely on your consent — for example, for marketing communications — you can withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6. Sharing Your Data

Zoya 99 does not sell your personal data. We share your data only in the following limited circumstances:

Payment Processors

We share necessary transaction data with bKash, Nagad and Rocket to process your deposits and withdrawals. These providers operate under their own privacy policies and are bound by strict data protection obligations.

Identity Verification Services

To comply with KYC requirements, we may share your identity documents with licensed third-party verification providers. These providers are contractually bound to use your data only for verification purposes.

Fraud Prevention Agencies

We may share data with fraud prevention and security agencies to protect the platform and our players from fraudulent activity. This sharing is carried out on the basis of our legitimate interests in maintaining a secure platform.

Legal and Regulatory Authorities

Zoya 99 will disclose personal data to law enforcement, regulatory bodies or courts when required to do so by applicable law or a valid legal order. We will notify you of such disclosures where we are legally permitted to do so.

7. Cookies and Tracking

Zoya 99 uses cookies and similar tracking technologies to operate the platform, remember your preferences and analyse how the service is used. Cookies are small text files stored on your device when you visit our website or use our app.

Types of Cookies We Use

• Essential cookies: Required for the platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and display options to improve your experience on Zoya 99.
• Analytics cookies: Help us understand how players use the platform so we can improve it. Data collected by analytics cookies is aggregated and anonymised.

You can manage cookie preferences through your browser settings. Disabling essential cookies may affect the functionality of the Zoya 99 platform. We do not use third-party advertising cookies or cross-site tracking technologies.

8. Data Security

Protecting your personal data is a top priority at Zoya 99. We implement a comprehensive set of technical and organisational security measures to safeguard your information against unauthorised access, loss, alteration or disclosure.

• All data transmitted between your device and Zoya 99 servers is encrypted using TLS 1.3.
• Personal data stored on our servers is encrypted at rest using AES-256 encryption.
• Access to personal data is restricted to authorised Zoya 99 staff on a strict need-to-know basis.
• Our systems are monitored continuously for suspicious activity and potential security incidents.
• We conduct regular security audits and penetration testing to identify and address vulnerabilities.
• All staff with access to personal data receive regular data protection and security training.

In the event of a data breach that is likely to affect your rights or freedoms, Zoya 99 will notify you without undue delay and take immediate steps to contain and remediate the breach.

9. Data Retention

Zoya 99 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying any legal, regulatory or reporting requirements.

• Active accounts: Personal data is retained for the full duration of your account with Zoya 99.
• Closed accounts: Following account closure, we retain your data for a minimum of five years to comply with anti-money laundering regulations and to handle any post-closure disputes.
• Transaction records: Financial transaction data is retained for seven years in line with standard financial record-keeping requirements.
• Support communications: Chat logs and email correspondence are retained for three years from the date of the interaction.
• Analytics data: Anonymised usage data used for platform analytics is retained indefinitely as it cannot be linked back to any individual.

When data is no longer required, it is securely deleted or irreversibly anonymised so that it can no longer be associated with you.

10. Your Rights

As a Zoya 99 player, you have the following rights in relation to your personal data. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request". We will respond within 30 days.

• Right of access: You can request a copy of all personal data we hold about you.
• Right to rectification: If any of your data is inaccurate or incomplete, you can ask us to correct it.
• Right to erasure: You can ask us to delete your personal data where there is no legitimate reason for us to continue holding it. Note that some data must be retained for legal compliance reasons.
• Right to restrict processing: You can ask us to pause processing of your data in certain circumstances, for example while a dispute is being resolved.
• Right to data portability: You can request your data in a structured, machine-readable format so you can transfer it to another service.
• Right to object: You can object to processing based on legitimate interests, including profiling for responsible gaming purposes.
• Right to withdraw consent: Where processing is based on your consent, you can withdraw it at any time without affecting prior processing.

11. Children's Privacy

Zoya 99 is strictly an adult platform. We do not knowingly collect personal data from anyone under the age of 18. If you are a parent or guardian and believe your child has registered on Zoya 99, please contact us immediately at [email protected]. We will close the account and delete all associated data promptly.

We use automated and manual age verification processes during registration to prevent underage access. We also encourage parents to use device-level parental controls to prevent minors from accessing online gaming platforms.

12. Changes to This Policy

Zoya 99 may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements or platform features. When we make material changes, we will notify registered players by email and display a prominent notice on the platform at least 7 days before the changes take effect.

The date at the top of this page always shows when the policy was last updated. We encourage you to review this Privacy Policy periodically. Continued use of the Zoya 99 platform after the effective date of any changes constitutes your acceptance of the updated policy.

13. Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or the way Zoya 99 handles your personal data, please get in touch:

• Email: [email protected]
• Subject line for data requests: "Data Rights Request"
• Live Chat: Available 24/7 via the Zoya 99 platform
• Response time: All privacy-related requests handled within 30 days

We take every privacy concern seriously and will do our best to resolve your query promptly and fairly. If you are not satisfied with our response, you have the right to escalate the matter to the relevant data protection authority.