Privacy Policy — How aiay9 Protects Your Data

1.1 Overview. When you interact with the aiay9 platform, we collect certain categories of personal information that are necessary to operate our services, comply with applicable regulations, and provide you with a secure and personalised experience. The categories of data we collect, and the context in which we collect them, are described below.

1.2 Sensitive Document Handling. Identity documents (NID scans, passport images, selfie verification photos) are classified as sensitive personal data. These are stored in encrypted form on access-controlled servers and are accessible only to authorised members of the aiay9 compliance and verification team. They are never shared with marketing partners, game providers, or any external party not directly involved in the verification process.

1.3 Minors. aiay9 does not knowingly collect personal data from individuals under the age of 18. If we become aware that a person under 18 has submitted personal data to the platform, we will immediately close the relevant account, delete all associated data, and report the incident internally. If you are a parent or guardian and believe your child has registered on the aiay9 platform, please contact us immediately at [email protected].

1.4 Data You Provide Voluntarily. In addition to mandatory registration data, you may voluntarily provide additional information through profile settings, responsible gaming preferences, or support communications. This voluntary data is used solely to improve your experience and is not shared beyond what is described in this Policy.

2.1 Primary Purposes. aiay9 collects and processes your personal data for the following primary purposes:

• Account creation and management: To register your account, verify your identity, and maintain your player profile on the platform.
• Transaction processing: To process deposits and withdrawals via bKash, Nagad, Rocket, Upay, and supported Bangladeshi banks, and to maintain accurate financial records for your account.
• Identity and age verification: To confirm that you are 18 years of age or older and that the identity you have registered is genuine, in compliance with our KYC obligations.
• Platform security: To detect and prevent fraud, money laundering, duplicate account creation, bonus abuse, and other prohibited activities described in our Terms & Conditions.
• Customer support: To respond to your queries, complaints, and support requests in a timely and informed manner.
• Responsible gaming: To monitor for indicators of problem gambling, enforce self-exclusion requests, apply deposit limits, and deliver responsible gaming interventions where appropriate.
• Regulatory compliance: To meet any applicable legal, regulatory, or audit requirements to which aiay9 is subject.

2.2 Secondary Purposes. With your consent (which you may withdraw at any time through your account settings), aiay9 may also use your contact information to:

• Send promotional offers, bonus notifications, and seasonal campaign communications relevant to players in Bangladesh (e.g., BPL season promotions, Eid bonus offers).
• Provide personalised game recommendations based on your playing history.
• Invite you to participate in voluntary surveys or feedback programmes designed to improve the platform.

2.3 Automated Decision-Making. aiay9 uses automated systems to flag unusual account activity, potential fraud patterns, and responsible gaming indicators. Where an automated flag results in a material account action (such as a temporary withdrawal hold), you have the right to request a manual review by a member of our compliance team by contacting [email protected].

2.4 Legal Basis for Processing. For players in Bangladesh, aiay9 processes personal data on the following legal bases:

• Contractual necessity: Processing required to deliver the services you have registered to receive (account management, payments, game access).
• Legitimate interests: Processing required for platform security, fraud prevention, and business analytics, where those interests do not override your fundamental privacy rights.
• Legal obligation: Processing required to comply with applicable laws, regulatory requests, or court orders.
• Consent: Processing for optional marketing communications and personalisation features, where you have given explicit opt-in consent.

3.1 Our Commitment. aiay9 does not sell, rent, or trade your personal data to any third party for commercial or marketing purposes. Data is shared only where strictly necessary for the operation of the platform, and only with partners who have agreed to handle your data with equivalent security standards and confidentiality obligations.

3.2 Categories of Third-Party Recipients. Your data may be shared with the following categories of service providers:

• Payment processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, and other supported Bangladeshi banking partners — solely for the purpose of processing your deposits and withdrawals. These partners receive only the minimum data required to execute a transaction.
• Identity verification services: Third-party KYC and document verification providers who assist in confirming the authenticity of identity documents submitted by players. All such providers operate under strict data processing agreements.
• Game providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and other game studios whose content is hosted on the aiay9 platform. Game providers may receive anonymised session data necessary for game operation and fairness certification. They do not receive your full identity data.
• Cloud infrastructure providers: Hosting and server infrastructure partners who store platform data in encrypted, access-controlled environments. These partners act as data processors under our instruction and are prohibited from using your data for any purpose beyond infrastructure provision.
• Fraud and security analytics: Specialist security service providers who assist in detecting fraudulent activity, bot usage, and suspicious betting patterns. Data shared is used exclusively for security purposes.
• Legal and regulatory bodies: Government agencies, courts, or regulatory authorities where aiay9 is legally required to disclose information pursuant to a lawful order or obligation.

3.3 International Data Transfers. Some of aiay9's infrastructure and service providers may be located outside Bangladesh. Where data is transferred internationally, aiay9 ensures that adequate safeguards are in place through contractual data protection clauses and security standards equivalent to those applied within Bangladesh. aiay9 does not authorise cross-border data transfers to countries that do not provide adequate data protection standards.

3.4 Business Transfers. In the event of a merger, acquisition, restructuring, or sale of all or part of the aiay9 business, your personal data may be transferred to the successor entity. In such an event, aiay9 will notify affected players via email or prominent platform notice prior to your data being transferred and becoming subject to a different privacy policy.

4.1 What Are Cookies. Cookies are small text files placed on your device by the aiay9 platform when you visit our website. They allow the platform to remember your preferences, maintain your session, and gather analytical data about how players interact with the site. aiay9 also uses similar technologies including web beacons, pixel tags, and local storage objects for equivalent purposes.

4.2 Types of Cookies We Use.

• Strictly Necessary Cookies: These are essential for the platform to function correctly. They enable core features such as account login session maintenance, security token validation, and payment flow continuity. These cookies cannot be disabled without breaking core platform functionality.
• Performance and Analytics Cookies: These collect anonymised data about how players navigate and use the platform — for example, which pages are visited most frequently, where players drop off during registration, and how long sessions last. This data helps aiay9 continuously improve platform usability and performance.
• Functional Cookies: These remember your preferences such as preferred game categories, deposit method, notification settings, and display preferences. Disabling functional cookies may result in a less personalised experience.
• Targeting and Marketing Cookies: Where you have given explicit consent, these cookies allow aiay9 to deliver relevant promotional content and measure the effectiveness of marketing campaigns targeted at players in Dhaka, Chittagong, Sylhet, and other cities across Bangladesh.

4.3 Managing Your Cookie Preferences. You can manage your cookie preferences at any time through your aiay9 account settings panel under "Privacy & Cookies". You may also configure your browser to block or delete cookies, though this may affect your ability to use certain features of the platform. Strictly necessary cookies cannot be disabled through account settings, as they are integral to platform security and session management.

4.4 Third-Party Cookies. Some cookies placed on your device when using the aiay9 platform may originate from third-party game providers or analytics services. aiay9 does not control third-party cookies and recommends that you review the privacy policies of any third-party service whose cookies may be present on your device when accessing game content.

5.1 Retention Periods. aiay9 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including satisfying any legal, regulatory, accounting, or reporting obligations. The following general retention guidelines apply:

• Active account data (identity, contact, payment details): Retained for the lifetime of your active aiay9 account plus a minimum of five years following account closure, in accordance with standard financial record-keeping requirements.
• Transaction records (deposit and withdrawal history, bet records): Retained for a minimum of seven years from the date of each transaction to satisfy financial audit and anti-money laundering record-keeping obligations.
• Identity verification documents (NID scans, passport images): Retained for a minimum of five years following account closure or the completion of the verification for which they were submitted, whichever is later.
• Customer support communications (chat transcripts, emails): Retained for three years from the date of the most recent communication in a given support thread, or for the duration of any open dispute or investigation, whichever is longer.
• Marketing communications data (where consent given): Retained until you withdraw marketing consent, after which your data is removed from all active marketing lists within 30 days. Historical opt-in records are retained for compliance purposes.
• Technical and session logs (IP addresses, device data): Retained for 90 days for routine security monitoring, and for up to three years in cases where a security investigation is ongoing.

5.2 Data Storage Location. All aiay9 player data is stored on encrypted servers maintained by vetted infrastructure providers. Data related to Bangladesh players is stored in compliance with applicable data sovereignty and privacy standards. aiay9 applies AES-256 encryption at rest for all sensitive personal data categories.

5.3 Data Deletion. Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be attributed to any individual. Where full deletion is requested by you prior to the end of the retention period, aiay9 will action the request to the extent permitted by applicable law — certain data categories (particularly financial records) must be retained for statutory minimum periods regardless of deletion requests.

6.1 Technical Safeguards. aiay9 implements industry-standard technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. Our security infrastructure includes:

• 256-bit SSL/TLS encryption for all data in transit between your device and the aiay9 platform.
• AES-256 encryption at rest for all sensitive personal data and identity documents stored on our servers.
• Multi-factor authentication (MFA) available for player accounts and mandatory for all aiay9 administrative staff accounts.
• Regular third-party penetration testing and security audits to identify and remediate vulnerabilities.
• Intrusion detection and prevention systems monitoring platform traffic around the clock.
• Role-based access controls ensuring that aiay9 staff can access only the data categories required for their specific role.
• Secure, encrypted backup systems with regular disaster recovery testing.

6.2 Organisational Safeguards. All aiay9 employees and contractors who handle personal data are bound by confidentiality agreements and receive regular training on data protection obligations. Access to sensitive player data is logged and subject to periodic review by our compliance team.

6.3 Breach Notification. In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected players, aiay9 will notify affected individuals without undue delay and will take all reasonable steps to contain and remediate the breach. Notifications will be sent to the email address registered on your account.

6.4 Your Role in Security. While aiay9 takes all reasonable technical steps to protect your data, you also play an important part in keeping your account secure. We recommend that you use a strong, unique password for your aiay9 account, enable two-factor authentication where available, never share your login credentials with any third party, and log out of your account when using shared or public devices. If you believe your account has been compromised, contact [email protected] immediately.

7.1 Overview of Rights. As a player on the aiay9 platform, you hold the following rights with respect to your personal data. These rights may be exercised by submitting a written request to [email protected] with the subject line "Data Subject Request — [Your Right]". aiay9 will acknowledge your request within 5 business days and respond substantively within 30 calendar days.

7.2 Limitations on Rights. Certain rights are subject to limitations. For example, the right to erasure does not apply to data aiay9 is legally required to retain, such as transaction records required under financial regulations, or data retained as part of an ongoing fraud or compliance investigation. Where a right cannot be fulfilled in full, aiay9 will inform you of the reason and the extent to which the request can be accommodated.

7.3 Identity Verification for Requests. To protect your privacy, aiay9 will verify your identity before processing any data subject request. You will be asked to confirm your registered email address, account username, and may be required to provide a copy of your identity document for higher-sensitivity requests such as data export or erasure.

8.1 Policy Updates. aiay9 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, platform functionality, applicable law, or regulatory requirements. When material changes are made, we will notify registered players by email to the address on file and by posting a prominent notice on the platform for a minimum of 14 days. The effective date at the top of this Policy will be updated accordingly.

8.2 Continued Use as Acceptance. Your continued use of the aiay9 platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree to any material change, you may close your account by contacting our support team prior to the effective date of the change.

8.3 Governing Law. This Privacy Policy is governed by and construed in accordance with applicable law in Bangladesh. Any disputes arising from this Policy that cannot be resolved through our internal process will be subject to the jurisdiction of the competent courts of Bangladesh.

8.4 Contact Us. For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact the aiay9 data team using the following details:

• Email: [email protected] (subject line: "Privacy Enquiry")
• Live Chat: Available 24/7 via your account dashboard
• Response Time: Within 5 business days for general enquiries; within 30 calendar days for formal data subject requests

8.5 Complaints. If you are not satisfied with how aiay9 has handled your personal data or responded to a data subject request, you have the right to raise a formal complaint through our internal complaints process. Details are available on our FAQ page or by contacting support directly.