Privacy Policy — ucb99

This Privacy Policy ("Policy") describes how ucb99 ("ucb99", "we", "us", "our"), operator of the online gaming platform at ucb99.app, collects, processes, stores, and protects personal data relating to users ("Player", "User", "you", "your") of our website, mobile interface, games, betting markets, and associated services (collectively, the "Platform"). By accessing the Platform or creating a registered account, you acknowledge that you have read this Policy and consent to the data practices described herein. If you do not agree with any part of this Policy, you must not use the Platform.

This Policy should be read alongside the ucb99 Terms and Conditions and Responsible Gaming Policy. Where a specific service or promotion carries its own supplementary privacy notice, that notice should be read in conjunction with this Policy. In the event of any conflict, the supplementary notice takes precedence for that specific service only.

1. Information We Collect

ucb99 collects personal data through several channels: directly from you when you register or interact with the Platform, automatically through your use of our services, and occasionally from trusted third-party sources for identity verification purposes. The categories of data we collect are set out below.

1.1 Registration & Account Data

When you create a ucb99 account, we collect the following information as mandatory fields required to operate your account:

• Full legal name as it appears on your government-issued identification
• Date of birth (to verify the 18+ age requirement)
• Valid email address used for account communications
• Bangladeshi mobile number linked to your account
• Username and hashed (never plain-text) password
• Preferred language (English) and currency (BDT)
• Residential address in Bangladesh (city, district)

1.2 Identity Verification (KYC) Data

To comply with our Know Your Customer obligations and to process withdrawals, we collect copies of identity documents. These may include:

• National Identity Card (NID) — front and back scan
• Bangladeshi Passport — bio-data page
• Driver's Licence — front and back scan
• Proof of address: utility bill, bank statement, or mobile financial service statement (bKash, Nagad, Rocket) dated within the last 90 days

1.3 Financial Transaction Data

We record all deposit and withdrawal transactions processed on the Platform, including:

• Payment method type (bKash, Nagad, Rocket, bank transfer)
• Registered mobile number or bank account associated with the payment method
• Transaction amounts in BDT, timestamps, and reference numbers
• Transaction status and any associated error codes

ucb99 does not store full card numbers, CVV codes, or complete bank account credentials. Payment authentication is handled directly by the respective payment providers (bKash, Nagad, Rocket, Dutch-Bangla Bank, City Bank, BRAC Bank, and others) through their own secure infrastructure.

1.4 Gameplay & Betting Activity Data

We record your activity on the Platform for operational, fairness, and responsible gaming purposes:

• Bets placed, odds accepted, game rounds played, and outcomes
• Stakes, winnings, losses, and running account balance
• Games and betting markets accessed (cricket, BPL, IPL, T20, slots, Pool Rummy, Monster Dice, live casino)
• Session duration, login and logout timestamps
• Responsible gaming tool usage (deposit limits set, self-exclusion requests, time-out activations)

1.5 Technical & Device Data

We automatically collect certain technical data when you access the Platform:

• IP address and approximate geographic location derived from IP
• Device type, operating system, and browser version
• Referring URL and on-site navigation path
• Page load times and error logs for performance monitoring
• Cookie identifiers and session tokens (see Section 5)

1.6 Communications Data

When you contact ucb99 support or respond to promotional communications, we retain:

• Content of emails sent to or received from [email protected]
• Live chat transcripts where applicable
• Records of complaints, disputes, and their resolution outcomes
• Marketing communication preferences (opt-in / opt-out status)

2. How We Use Your Data

ucb99 uses personal data only for legitimate, defined purposes directly related to operating the Platform and fulfilling our obligations to players. The table below summarises the primary use cases:

Purpose	Data Used	Legal Basis
Account creation and management	Registration data, contact details	Contract performance
Age and identity verification (KYC)	KYC documents, date of birth	Legal obligation
Processing deposits and withdrawals	Financial transaction data	Contract performance
Delivering gameplay and betting services	Gameplay data, account balance	Contract performance
Fraud detection and prevention	Transaction data, device data, IP address	Legitimate interest
Responsible gaming monitoring	Gameplay data, session data, limit settings	Legal obligation / legitimate interest
Customer support and dispute resolution	Communications data, account records	Contract performance
Platform security and abuse prevention	Device data, IP address, login logs	Legitimate interest
Service improvement and analytics	Anonymised technical and gameplay data	Legitimate interest
Promotional communications (opted-in players only)	Email address, communication preferences	Consent

ucb99 does not use your personal data for automated profiling that produces legal or similarly significant effects on you without a human review step. Where algorithmic tools are used to flag accounts for responsible gaming review or fraud investigation, a trained member of our compliance team reviews the flag before any action is taken on your account.

3. Legal Basis for Processing

Every processing activity carried out by ucb99 rests on one of the following legal grounds:

• Contract performance: Processing necessary to create and manage your account, deliver the gaming and betting services you have requested, and process financial transactions.
• Legal obligation: Processing required to comply with applicable laws, including age verification, anti-money-laundering (AML) checks, and record-keeping obligations.
• Legitimate interests: Processing necessary for fraud prevention, platform security, abuse detection, and aggregated analytics — provided these interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing that relies on your freely given, specific, and informed consent — such as sending you promotional emails about bonuses, seasonal offers (Eid, BPL, IPL, Pohela Boishakh), or new game launches. You may withdraw consent at any time by contacting [email protected] or using the unsubscribe link in any marketing email.

4. Data Sharing & Disclosure

ucb99 does not sell, rent, or trade personal data. We share data with third parties only in the limited circumstances set out below, and only to the minimum extent necessary for the stated purpose.

4.1 Payment Service Providers

To process deposits and withdrawals, we share relevant transaction data with the payment partners you select, including bKash, Nagad, Rocket (Dutch-Bangla Bank Mobile Banking), BRAC Bank, City Bank, Islami Bank, and Sonali Bank. The name on your ucb99 account is verified against the name registered with your payment provider. Each payment partner operates under its own privacy policy and security standards.

4.2 Identity Verification Partners

ucb99 may use third-party KYC verification services to cross-check identity documents submitted by players. These partners are contractually obligated to process data solely for verification purposes and may not use it for any other purpose, including their own marketing activities.

4.3 Technology and Game Providers

Our platform is powered by licensed software from providers including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Ezugi. Anonymised session and gameplay data may be shared with these providers for the purpose of game delivery, RNG certification, and technical support. No personally identifiable information is shared beyond what is technically necessary for game delivery.

4.4 Legal and Regulatory Disclosures

ucb99 may disclose personal data to government authorities, law enforcement agencies, courts, or regulators where required to do so by a valid legal obligation, court order, or regulatory direction. We will notify affected players of such disclosures where we are legally permitted to do so.

4.5 Business Transfers

In the event that ucb99 undergoes a merger, acquisition, or sale of assets, player data may form part of the transferred assets. In such circumstances, we will notify affected players by email at the registered address on their account at least 30 days prior to any transfer, and players will have the opportunity to request deletion of their data before the transfer takes effect.

5. Cookies & Tracking Technologies

ucb99 uses cookies and similar tracking technologies (such as local storage and session tokens) on our Platform. These technologies help us operate the site securely, remember your session preferences, and understand how the Platform is used in aggregate. We do not use third-party advertising cookies or behavioural tracking cookies.

5.1 Types of Cookies We Use

Cookie Type	Purpose	Duration
Strictly Necessary	Session management, login authentication, CSRF protection, fraud prevention tokens	Session / up to 24 hours
Functional	Remembering your language preference (English), currency (BDT), and responsible gaming settings	Up to 12 months
Analytics	Anonymised page-view counts, navigation paths, and feature usage to improve the Platform. No personally identifiable data is stored in analytics cookies.	Up to 13 months

Strictly necessary cookies cannot be disabled as they are essential for secure operation of the Platform. Functional and analytics cookies may be declined via your browser settings; however, disabling functional cookies may affect your experience (for example, your preferred settings may not be saved between sessions).

5.2 Managing Cookies

You can manage or delete cookies through your browser settings at any time. Most modern browsers allow you to view which cookies are stored, block cookies from specific domains, and clear all stored cookies. Detailed guidance on cookie management is available in the help documentation of your browser. Please note that clearing session cookies will log you out of your ucb99 account immediately.

6. Data Retention

ucb99 retains personal data for as long as necessary to fulfil the purpose for which it was collected, or to comply with applicable legal, regulatory, accounting, or reporting obligations. The specific retention periods for key data categories are as follows:

• Active account data: Retained for the full duration of your account's active status.
• KYC and identity documents: Retained for a minimum of 5 years after account closure to comply with anti-money-laundering record-keeping obligations.
• Financial transaction records: Retained for a minimum of 7 years after the transaction date for accounting and regulatory purposes.
• Gameplay and betting history: Retained for 3 years after account closure for dispute resolution and responsible gaming audit purposes.
• Support communications: Retained for 2 years after the resolution of the relevant issue or query.
• Marketing consent records: Retained for the duration of your opted-in status plus 3 years after withdrawal of consent, for evidentiary purposes.
• Technical logs (IP, device data): Retained for up to 90 days for security monitoring, then anonymised or deleted.

After the applicable retention period has expired, personal data is securely deleted or irreversibly anonymised so that it can no longer be linked to you as an individual. Anonymised, aggregated data may be retained indefinitely for statistical purposes.

7. Your Privacy Rights

As a user of the ucb99 Platform, you hold the following rights with respect to your personal data. To exercise any of these rights, please submit a written request to [email protected] from the email address registered on your account. We will verify your identity before processing any request and respond within 30 calendar days.

• Right of Access: You may request a copy of all personal data ucb99 holds about you, including the categories of data, the purposes for which it is processed, and any third parties with whom it has been shared.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you may request that it be corrected. For account name corrections, a supporting identity document will be required.
• Right to Erasure: You may request deletion of your personal data where: it is no longer necessary for the purpose it was collected; you withdraw consent (where consent was the legal basis); or the data has been unlawfully processed. Note that erasure requests cannot be fulfilled where data is required to meet a legal obligation — for example, financial transaction records subject to a 7-year retention requirement cannot be deleted on request alone.
• Right to Restrict Processing: You may request that ucb99 restrict processing of your personal data in certain circumstances — for example, while a dispute about the accuracy of data is being resolved.
• Right to Data Portability: Where processing is based on your consent or on contract performance and is carried out by automated means, you may request a copy of your data in a structured, commonly used, machine-readable format (CSV or JSON).
• Right to Object: You may object at any time to processing of your personal data where the legal basis is legitimate interests. You also have an unconditional right to object to processing for direct marketing purposes; such objections will be acted upon immediately.
• Right to Withdraw Consent: Where processing is based solely on your consent (for example, marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

8. Data Security Measures

ucb99 takes the security of your personal data seriously and implements a layered set of technical and organisational measures to protect it against unauthorised access, accidental loss, alteration, disclosure, or destruction. Our principal security measures include:

8.1 Technical Safeguards

• 256-bit SSL/TLS encryption on all data transmitted between your browser or device and our servers.
• Password hashing using industry-standard one-way algorithms (bcrypt). ucb99 never stores passwords in plain text and support staff cannot view your password.
• Tokenised payment processing — raw payment credentials (bKash PIN, Nagad PIN, bank account numbers) are never stored on ucb99 servers; payment authentication occurs on the respective provider's secure infrastructure.
• Firewalls, intrusion detection systems, and regular vulnerability scanning on all production infrastructure.
• Access controls — internal access to personal data is restricted to personnel with a verified and documented business need. All internal access is logged and periodically audited.

8.2 Organisational Safeguards

• Regular data protection training for all staff with access to player data.
• Formal data breach response procedures. In the event of a breach that is likely to result in risk to your rights and freedoms, we will notify you within 72 hours of becoming aware of the breach.
• Third-party security assessments and penetration testing conducted periodically by independent specialists.
• Documented data processing records maintained in accordance with our compliance obligations.

8.3 Your Role in Security

While ucb99 takes all reasonable steps to protect your data, the security of your account also depends on you. You are responsible for keeping your login credentials confidential and for ensuring that no unauthorised person has access to your account. If you suspect that your account has been compromised, contact [email protected] immediately so we can freeze the account pending a security review.

8.4 Updates to This Policy

ucb99 reserves the right to update this Privacy Policy to reflect changes in our data practices, service offerings, or applicable legal requirements. Material changes will be communicated to registered players by email at the address on their account at least 14 days before the new policy takes effect. The "Last updated" date at the top of this Policy reflects the date of the most recent revision. Continued use of the Platform following notification of material changes constitutes acceptance of the updated Policy.