199bat Privacy Policy

1. Introduction

199bat ("the Platform", "we", "us", "our") operates the online gaming platform accessible at 199bat.app, providing cricket sports betting, live casino, slot games, fishing games, crash games, and related gaming services to players located in Bangladesh and other permitted jurisdictions. In delivering these services, 199bat necessarily collects, stores, and processes certain categories of personal data relating to registered players and platform visitors.

This Privacy Policy sets out, in accordance with internationally recognised data protection principles, the types of personal data we collect, the purposes for which that data is processed, the parties with whom it may be shared, the period for which it is retained, and the rights available to you as a data subject. This policy applies to all users of the 199bat platform, including registered account holders, visitors who browse the platform without registering, and individuals who contact the 199bat support team.

By registering an account with 199bat or continuing to use the platform, you acknowledge that you have read and understood this Privacy Policy and that you consent to the collection and use of your personal data as described herein. If you do not agree with any part of this policy, you should not register an account or use the platform.

This Privacy Policy should be read alongside the 199bat Terms & Conditions, which govern your use of the platform as a whole. In the event of any conflict between this Privacy Policy and the Terms & Conditions with respect to data handling, this Privacy Policy shall prevail.

2. Personal Data We Collect

199bat collects personal data in the following categories, depending on the nature of your interaction with the platform:

2.1 Identity Data

• Full legal name as it appears on a government-issued identity document
• Date of birth (used for age verification — players must be 18 or older)
• National identity card (NID) number or passport number, where verification is required
• Photograph or scanned copy of identity documentation, where provided for KYC purposes

2.2 Contact Data

• Mobile phone number (primary account contact and OTP delivery)
• Email address, where provided
• Residential address or city of residence, where provided during verification

2.3 Financial Data

• Mobile financial service account details (e.g., bKash, Nagad, Rocket, Upay account identifiers) used for deposits and withdrawals
• Bank account details , where provided for bank transfer transactions
• Transaction history including deposit amounts, withdrawal amounts, dates, and payment method references
• Card details (last four digits only; full card numbers are never stored by 199bat directly — card processing is handled by certified third-party payment processors)

2.4 Technical Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser version
• Session timestamps and duration
• Unique device identifiers where applicable

2.5 Usage & Behavioural Data

• Pages and game sections visited on the platform
• Betting and gaming activity, including games played, bet amounts, outcomes, and session patterns
• Bonus and promotion usage history
• Customer support interaction records, including chat logs and email correspondence

2.6 Communications Data

• Records of any messages, queries, or complaints submitted to the 199bat support team
• Any documents or files you voluntarily upload or share with us, including identity verification documents

3. How We Collect Your Data

199bat collects personal data through the following channels:

Collection Channel	Examples of Data Collected
Direct registration	Name, mobile number, date of birth provided when creating your account
Identity verification	NID, passport scans, selfie photos submitted during KYC review
Payment transactions	bKash/Nagad/Rocket account IDs, bank references, transaction amounts
Platform activity	Games played, bets placed, session timestamps, pages visited
Cookies & tracking tools	IP address, device type, browser fingerprint, session cookies
Customer support	Name, account ID, and issue description provided when contacting support
Third-party sources	Identity verification results from KYC providers; fraud signals from payment processors

4. Purpose of Processing Your Data

199bat processes personal data only for lawful, specified purposes. The primary purposes for which your data is used are as follows:

• Account creation and management: To register your account, authenticate your identity, maintain your account settings, and ensure the ongoing integrity of your player profile.
• Age and identity verification: To confirm that you meet the minimum age requirement of 18 years and that you are who you claim to be, in accordance with our responsible gaming obligations.
• Payment processing: To facilitate deposits and withdrawals via bKash, Nagad, Rocket, Upay, and banking channels, and to maintain an accurate transaction history for your account.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, multi-accounting, bonus abuse, and other prohibited conduct on the platform.
• Responsible gaming compliance: To monitor gaming activity patterns that may indicate problem gambling behaviour, and to apply any self-exclusion, deposit limit, or cooling-off tools that you have activated on your account.
• Customer support: To respond to your enquiries, resolve disputes, and maintain records of communications for quality assurance purposes.
• Platform improvement: To analyse aggregate usage patterns and improve the design, performance, and content of the 199bat platform over time.
• Legal and regulatory compliance: To fulfil any obligations imposed on the platform by applicable law, including the preservation of records required for anti-money laundering (AML) and counter-terrorism financing (CTF) compliance purposes.
• Marketing communications: Where you have separately opted in to receive promotional communications from 199bat, to deliver personalised offers, bonus notifications, and platform updates. You may opt out at any time.

5. Legal Basis for Processing

199bat relies on the following legal bases when processing your personal data, depending on the specific processing activity:

• Contractual necessity: Processing that is necessary to deliver the services you have requested under the Terms & Conditions, including account management, payment processing, and gaming service delivery.
• Legitimate interests: Processing carried out for the purpose of fraud prevention, platform security, abuse detection, and improving the quality of the platform, where these interests are not overridden by your fundamental rights and freedoms.
• Legal obligation: Processing required to comply with applicable laws, including identity verification requirements, financial record-keeping obligations, and responses to lawful requests from competent authorities.
• Consent: Processing for purposes such as optional marketing communications, where you have given clear and freely withdrawable consent. Where consent is the basis, you may withdraw it at any time by contacting [email protected] without affecting the lawfulness of processing that occurred before withdrawal.

6. How We Share Your Data

199bat does not sell, rent, or trade your personal data to third parties for their own marketing purposes under any circumstances. Personal data is shared with third parties only in the following limited circumstances:

6.1 Service Providers

We share data with carefully selected third-party service providers who assist us in operating the platform. These include:

• Payment processors: bKash, Nagad, Rocket, Upay, and banking partners require transaction data to facilitate deposits and withdrawals.
• Identity verification providers: Third-party KYC service providers receive identity documentation to conduct age and identity verification on our behalf.
• Game software providers: Game providers such as Evolution Gaming, Pragmatic Play, Ezugi, NetEnt, Spribe, and Microgaming may receive your account identifier and game session data to deliver their games within the 199bat platform environment.
• Technology infrastructure providers: Cloud hosting, content delivery, and cybersecurity providers who process data on our behalf under strict data processing agreements.

All third-party service providers are contractually obligated to process your data only for the purposes specified and to apply security measures that are no less stringent than those used by 199bat.

6.2 Legal and Regulatory Disclosures

199bat may disclose personal data to competent authorities, law enforcement bodies, or regulatory agencies where required to do so by applicable law, court order, or other lawful process. We will provide only the minimum data necessary to satisfy such a request and will, where legally permissible, notify you that such a disclosure has been made.

6.3 Business Transfers

In the event that 199bat undergoes a merger, acquisition, restructuring, or sale of assets, personal data held by the platform may be transferred to the acquiring entity as part of that transaction, subject to equivalent privacy protections remaining in place. You will be notified of any such transfer and of any material changes to the way your data is handled as a result.

7. Data Retention

199bat retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by applicable law. The following general retention periods apply:

Data Category	Retention Period	Reason
Account registration data	Duration of account + 5 years after closure	Legal obligation, AML compliance
Identity verification documents	Duration of account + 5 years after closure	Regulatory KYC requirements
Financial transaction records	Minimum 5 years from transaction date	AML/CTF compliance, dispute resolution
Gaming activity logs	3 years from the date of activity	Responsible gaming monitoring, audits
Support communications	3 years from the date of the interaction	Quality assurance, dispute evidence
Cookie and session data	Up to 12 months from collection	Platform performance and security
Marketing consent records	Until consent is withdrawn + 2 years	Evidence of lawful processing basis

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual. Where data has been anonymised, the resulting aggregate data may be retained and used for analytical purposes without restriction.

8. Data Security

199bat applies a range of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption: All data transmitted between your device and the 199bat platform is encrypted using industry-standard SSL/TLS protocols. Look for the padlock icon in your browser address bar to confirm that your session is secured.
• Password hashing: Account passwords are never stored in plain text. They are processed using a one-way cryptographic hashing algorithm so that even internal staff cannot read your password.
• Access controls: Access to personal data within 199bat's systems is restricted to authorised staff on a strict need-to-know basis. All internal data access is logged and audited.
• Data segmentation: Financial data and identity documents are stored in separately secured environments from general account data, with additional access controls in place.
• Regular security reviews: The platform undergoes regular security assessments to identify and address potential vulnerabilities before they can be exploited.

While 199bat takes all reasonable steps to secure your data, no online platform can guarantee absolute security. You are also responsible for maintaining the security of your account by keeping your login credentials confidential and using a strong, unique password. If you suspect that your account has been compromised, please contact [email protected] immediately.

9. Cookies & Tracking Technologies

199bat uses cookies and similar tracking technologies to enhance your experience on the platform, maintain your session while you are logged in, and gather aggregate analytics data to help us improve the platform's performance and usability.

9.1 Types of Cookies Used

• Essential cookies: These are strictly necessary for the platform to function. They enable you to log in, maintain your session, and navigate between pages. Without these cookies, core platform features cannot operate. These cookies cannot be disabled.
• Functional cookies: These remember your preferences, such as display language, odds format, and game lobby settings, to personalise your experience on return visits.
• Analytics cookies: These collect anonymous data about how players interact with the platform — such as which pages are visited most frequently and which game categories attract the most activity. This data is used exclusively to improve the platform and is never used to identify individual users.
• Security cookies: These assist in detecting and preventing fraudulent activity and abuse, including the identification of suspicious login patterns and unusual account behaviour.

9.2 Managing Cookies

You can control non-essential cookies through your browser settings. Most modern browsers allow you to block or delete cookies stored on your device. Please note that disabling essential cookies will prevent you from logging in and using core platform features. Detailed guidance on managing cookies is available in the help documentation for your specific browser.

10. Your Data Protection Rights

As a data subject, you hold the following rights with respect to your personal data held by 199bat. To exercise any of these rights, please contact our support team at [email protected] with the subject line "Data Rights Request" and your registered account details for identity verification purposes.

• Right of access: You have the right to request a copy of the personal data that 199bat holds about you, together with information about how and why it is being processed.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected or completed without undue delay.
• Right to erasure: In certain circumstances — for example, where data is no longer necessary for the purpose for which it was collected, or where you have withdrawn consent — you may request that your personal data be deleted. Note that this right is subject to our legal retention obligations; some data must be retained for a minimum period regardless of an erasure request.
• Right to restriction: You may request that processing of your data be restricted in certain circumstances — for example, while the accuracy of data you have contested is being verified.
• Right to data portability: Where processing is based on consent or contract and is carried out by automated means, you may request that your data be provided to you in a structured, machine-readable format.
• Right to object: You have the right to object to processing that is based on our legitimate interests, including profiling for fraud prevention purposes, where your individual circumstances justify such an objection.
• Right to withdraw consent: Where processing is based solely on your consent — for example, for optional marketing communications — you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

199bat will respond to all verified data rights requests within 30 days of receipt. Where a request is complex or numerous, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reasons for it.

11. Minors and the 18+ Requirement

The 199bat platform is strictly intended for adults aged 18 years and above. We do not knowingly collect personal data from individuals under the age of 18. Age verification is a mandatory step in our account and withdrawal processes, and any account found to be held by a person under the age of 18 will be immediately closed.

If you are a parent or guardian and believe that a minor in your care has registered an account with 199bat and provided personal data to us, please contact us immediately at [email protected]. We will take prompt action to close the account and delete any associated personal data, subject to any legal retention obligations that may apply.

12. International Data Transfers

199bat operates as an internationally managed platform. In the course of delivering services to players in Bangladesh, your personal data may be transferred to and processed in countries outside Bangladesh where 199bat's infrastructure providers, game providers, or KYC partners are based. Such countries may not have data protection laws equivalent in scope to those you may be familiar with.

Where international transfers occur, 199bat takes reasonable steps to ensure that appropriate safeguards are in place, including the use of contractual clauses that require recipient parties to protect your data to a standard consistent with this Privacy Policy. By using the 199bat platform, you acknowledge and consent to such transfers as described in this section.

13. Changes to This Privacy Policy

199bat may update this Privacy Policy from time to time to reflect changes in the platform, applicable law, or our internal data handling practices. Where changes are material — meaning they substantially affect the way your personal data is collected, used, or shared — we will provide reasonable notice through the platform or via your registered contact details prior to the changes taking effect.

Minor updates such as corrections to typographical errors, clarifications that do not alter the substance of any clause, or updates to contact details may take effect immediately upon publication. The "Last Updated" date at the top of this document will always reflect the date of the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how your data is being protected.

Your continued use of the 199bat platform following any update to this Privacy Policy constitutes your acceptance of the revised version. If you do not accept the changes, you should cease using the platform and may request account closure in accordance with the Terms & Conditions.

14. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data that 199bat holds about you, please contact our support team using the details below. We are committed to responding to all privacy-related enquiries promptly and transparently.

• Contact method: Email only (no postal address; no telephone support line)
• Email address: [email protected]
• Subject line for data requests: "Data Rights Request – [Your Registered Mobile Number]"
• Response time: Within 30 days of receipt of a verified request
• Support hours: 24 hours a day, 7 days a week (Bangladesh Standard Time, UTC+6)

Please note that to protect your privacy and the security of your account, all data rights requests must be submitted from the mobile number or email address registered to your 199bat account, or be accompanied by sufficient information to verify your identity before we can act on the request.