Introduction

99ab is committed to protecting the personal information of users who access and use our online gambling platform. This Privacy Policy explains what data we collect, how we use it, when we disclose it, how it is safeguarded, and the rights available to individuals in relation to their data. By using our services, you acknowledge and agree to the processing described herein.

Data Controller and Contact Information

99ab acts as the data controller for the personal information collected in connection with our services. You may contact us at [email protected] with inquiries about this Policy, requests to exercise data rights, or concerns regarding our data handling practices. We may appoint a Data Protection Officer or designate a contact point within the privacy team to coordinate requests and ensure regulatory compliance.

What Personal Data We Collect

  • Identification and account data: name, date of birth, nationality, username, email address, postal or billing address, and contact numbers.
  • Identity verification and security data: government-issued identification documents, proof of address, and related authentication records.
  • Financial and transactional data: payment method details (where applicable), transaction history, and last four digits of payment instruments used.
  • Account and usage data: login history, device identifiers, IP address, browser type, regional settings, language preferences, and pages visited on our platform.
  • Communication data: correspondence with our support channels, chat transcripts, and feedback submissions.

How We Collect Personal Data

  • Direct collection: data provided by you when creating an account, depositing funds, or communicating with us.
  • Automatic collection: technical logs and analytics generated by your use of the platform, including cookies and IP data.
  • Third-party sources: identity verification and anti-fraud checks conducted by approved service providers as necessary to establish eligibility and prevent prohibited conduct.

Purposes for Processing Personal Data

  • To provide and manage our gambling services, maintain your account, and process deposits and withdrawals.
  • To secure the platform, detect unauthorized activity, and prevent fraud and money laundering in accordance with applicable laws.
  • To verify your identity and protect minors from access to gambling services.
  • To communicate about account activity, service updates, and regulatory or legal notices.
  • To improve our products and services, including platform performance and user experience.
  • To market our products and promotions to you where you have given consent or where permitted by law; you may withdraw consent or opt out at any time.

Legal Bases for Processing Personal Data

  • Contractual necessity: processing required to provide and operate the gambling services and fulfill our contractual obligations with you.
  • Legal compliance: processing needed to comply with applicable laws, including anti-money laundering, age verification, and regulatory reporting.
  • Legitimate interests: processing for security, fraud prevention, system integrity, and service improvements, subject to proportionality and your rights.
  • Consent: processing for marketing communications and targeted offers where you have expressly consented.

Sharing of Personal Data

  • Service providers: we may disclose data to processors and partners (payment processors, identity verification providers, hosting and IT services) to deliver our services.
  • Regulatory and law enforcement: we may disclose data as required by law, regulation, or legal process, or to protect our rights or the rights of others.
  • Affiliates and corporate transfers: in connection with corporate transactions, reorganizations, or to provide unified services across our group, subject to appropriate safeguards.
  • Consent and instructions: data may be disclosed to third parties where you have given explicit consent or direction.

International Transfers and Safeguards

Your personal data may be stored or processed in jurisdictions outside your residence. In such cases, we implement safeguards designed to protect the data, including contractual arrangements and recognized transfer mechanisms appropriate to the data protection regime in force. By using our services, you consent to transfers of your information to jurisdictions outside your location.

Data Security

We apply technical and organizational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. This includes encryption for data in transit and at rest where feasible, access controls, secure development practices, and regular security reviews. We require our personnel and service providers to implement appropriate safeguards consistent with the sensitivity of the data.

Data Retention

We retain personal data only for as long as necessary to provide the services and to fulfill legitimate business purposes and regulatory obligations. Retention periods are determined by the type of data, the purposes for which it was collected, and applicable legal requirements. When data is no longer needed, it is securely deleted or anonymized.

Your Rights as a Data Subject

  • Right of access: you may request a copy of the personal data we hold about you.
  • Right to rectification: you may request correction of inaccurate or incomplete data.
  • Right to erasure: you may request deletion where there is no compelling reason for continued processing, subject to legal allowances.
  • Right to restriction of processing: you may request limits on processing under certain circumstances.
  • Right to data portability: you may request a structured, commonly used, machine-readable copy of your data.
  • Right to object: you may object to processing based on legitimate interests or direct marketing.
  • Right to withdraw consent: for processing based on consent, you may withdraw consent at any time.
  • Right to lodge a complaint: you may lodge a complaint with the relevant supervisory authority if you believe your rights have been violated.

Requests to exercise these rights should be submitted through your account settings or by contacting [email protected]. We will respond within a reasonable timeframe, and in any case no later than 30 days, with assistance or a determination.

Cookies and Tracking Technologies

We use cookies and similar technologies to enable login, authentication, analytics, and platform functionality. Cookies are set only after your consent where required, and they expire within a maximum of four weeks. You may manage cookie preferences through your browser or our platform controls. We will provide a clear notice before deploying cookies that are not strictly necessary for the provision of the service.

Marketing and Communications

With your consent or as permitted by law, we may send you offers, promotions, and updates by email or other channels. You may withdraw consent or opt out of marketing communications at any time. We will not share your personal data with third parties for their marketing purposes without your explicit consent.

Minors and Age Verification

We do not knowingly collect personal data from individuals under the minimum gambling age. We implement age verification steps during onboarding and may suspend or terminate accounts that fail verification, in accordance with applicable laws and our policy against underage gambling.

Changes to This Policy

We may update this Privacy Policy from time to time. When changes are material, we will provide notice on our platform. Your continued use of our services after such notice constitutes acceptance of the updated policy.

Regulatory Information

99ab operates in accordance with the laws of Curacao and holds a license under regulatory supervision appropriate for online gambling services. We comply with applicable data protection laws and regulatory requirements relevant to our activities, including reporting and identity verification obligations as required by law.