Privacy Policy — How sq999 Protects Your Data

This Privacy Policy ("Policy") describes how sq999 ("sq999", "we", "us", "our") collects, processes, stores, and protects personal data relating to individuals ("User", "Player", "you", "your") who access or use the sq999 online casino and sports betting platform, available at sq999.io and any associated subdomains or mobile-optimised interfaces thereof.

sq999 is committed to protecting the privacy and personal data of every player across Bangladesh and all other markets in which sq999 operates. This Policy is written in plain English to ensure that you fully understand your rights and our obligations. Where technical or legal terminology is unavoidable, we have explained its meaning in context.

This Policy should be read alongside the sq999 Terms & Conditions, which govern your use of the platform as a whole, and the sq999 Responsible Gaming Policy. Both documents are incorporated into this Policy by reference. In the event of any conflict between a translated version of this Policy and the English version, the English version shall prevail.

sq999 reserves the right to update this Policy periodically to reflect changes in applicable data protection law, the services we offer, or the ways in which we process personal data. The date at which this Policy was last updated is displayed prominently at the top of the page. Your continued use of the sq999 platform after a revised Policy has been published constitutes your acceptance of the revised terms.

For the purposes of this Privacy Policy, sq999 is the data controller in respect of all personal data collected from players who use the sq999 platform. As data controller, sq999 determines the purposes and means of processing your personal data and is responsible for ensuring that processing is carried out lawfully, fairly, and transparently.

If you have any questions about how sq999 processes your personal data, or if you wish to exercise any of your data subject rights as described in Section 10 of this Policy, you may contact the sq999 Data Privacy team using the contact details provided in Section 15.

sq999 collects personal data from you in three principal ways: data you provide directly to us, data collected automatically through your use of the platform, and data received from authorised third-party sources. The categories of personal data collected are detailed in the table below.

sq999 does not intentionally collect Sensitive Personal Data (also referred to as Special Category Data), including data relating to racial or ethnic origin, political opinions, religious beliefs, health conditions, or biometric identifiers, except where you voluntarily provide such information in the context of a responsible gaming support request, in which case such data is handled with heightened care and used solely for the purpose of providing that support.

sq999 uses the personal data it collects for the following purposes:

• Account creation and management: To register your account, verify your identity, maintain your account profile, and enable you to log in and use the sq999 platform.
• Transaction processing: To process deposits and withdrawals via bKash, Nagad, Rocket, Upay, and partner banks; to reconcile your account balance; and to maintain a complete and accurate record of your financial activity on the platform.
• KYC and AML compliance: To verify your identity and age in accordance with applicable anti-money laundering (AML) and know-your-customer (KYC) obligations, and to detect and prevent financial crime.
• Platform operation and improvement: To deliver the games, betting markets, and other features you use; to monitor platform performance; to diagnose and fix technical issues; and to develop new features and improve existing ones based on aggregated usage analytics.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, multi-accounting, bonus abuse, money laundering, and other prohibited conduct as defined in the sq999 Terms & Conditions.
• Responsible gaming: To monitor your gaming patterns and, where automated systems or human reviewers identify indicators of potential problem gambling, to proactively reach out with responsible gaming resources and to apply any responsible gaming tools you have activated on your account.
• Customer support: To respond to your queries, complaints, and disputes submitted via live chat, email, or any other support channel made available on the sq999 platform.
• Marketing communications (opt-in only): To send you promotional offers, bonus announcements, tournament invitations, and other marketing communications by email, SMS, or push notification, but only where you have given your explicit prior consent to receive such communications. You may withdraw this consent at any time.
• Legal and regulatory compliance: To comply with applicable laws, regulations, court orders, and lawful requests from competent authorities, including obligations under Bangladesh's applicable financial and digital commerce regulations.

sq999 processes your personal data on the following legal bases, depending on the nature and purpose of the processing activity:

• Contractual necessity: Processing required to perform the contract between sq999 and you as a registered player — including account management, transaction processing, game delivery, and customer support — is carried out on the basis that it is necessary for the performance of that contract.
• Legal obligation: Processing required to comply with applicable laws, including AML obligations, KYC verification requirements, and lawful requests from regulatory or law enforcement authorities, is carried out on the basis of legal obligation.
• Legitimate interests: Processing carried out for fraud prevention, platform security, abuse detection, internal analytics, and responsible gaming monitoring is carried out on the basis of sq999's legitimate business interests, provided those interests are not overridden by your rights and interests.
• Consent: Processing for optional purposes — including marketing communications, optional analytics cookies, and the voluntary provision of health-related information in a responsible gaming context — is carried out on the basis of your freely given, specific, informed, and unambiguous consent. You may withdraw consent for any consent-based processing at any time without penalty.

sq999 does not sell, rent, or trade your personal data to unaffiliated third parties. sq999 may share your personal data with the following categories of authorised third parties, strictly on a need-to-know basis and subject to appropriate contractual data protection obligations:

• Payment service providers: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, City Bank, and other payment partners integrated into the sq999 platform, for the purpose of processing your deposit and withdrawal requests.
• Identity verification providers: Third-party KYC and document verification service providers engaged by sq999 to assist with age and identity checks required under AML regulations.
• Game studios and technology providers: Game content providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi receive session tokens and anonymised player identifiers necessary to deliver game content. These providers do not receive your full personal profile.
• Fraud and risk management providers: Third-party fraud detection and risk scoring services that analyse transaction patterns and device fingerprints to assist sq999 in identifying suspicious activity.
• Analytics service providers: Aggregated, pseudonymised usage data may be shared with analytics providers to help sq999 understand how the platform is used and improve the user experience. No directly identifying data is included in such transfers.
• Legal and regulatory authorities: sq999 will disclose personal data to competent law enforcement agencies, regulators, or courts where required to do so by law, or where sq999 determines in good faith that such disclosure is necessary to protect the rights, property, or safety of sq999, its players, or the public.
• Professional advisors: Lawyers, auditors, accountants, and other professional advisors engaged by sq999 on a confidential basis, to the extent necessary for the provision of their services.

All third parties with whom sq999 shares personal data are required to maintain appropriate technical and organisational security measures and to process that data only for the specific purposes authorised by sq999. sq999 conducts due-diligence assessments on key data processing partners on a periodic basis.

sq999 operates servers and engages service providers in multiple jurisdictions. As a result, your personal data may be transferred to, and processed in, countries other than Bangladesh. Where such international transfers occur, sq999 takes the following steps to ensure your data remains protected to a standard at least equivalent to that which applies within Bangladesh:

• Entering into data processing agreements with all recipients that incorporate appropriate data transfer safeguards, including standard contractual clauses where applicable.
• Carrying out transfer impact assessments prior to any new international data transfer arrangement to evaluate the adequacy of data protection in the destination jurisdiction.
• Applying encryption and pseudonymisation to data in transit and at rest, regardless of the jurisdiction in which it is processed.

By using the sq999 platform, you acknowledge and consent to the transfer of your personal data to jurisdictions outside Bangladesh as described in this section, subject to the safeguards described above.

sq999 retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be attributed to any identifiable individual. Where data has been anonymised, sq999 may retain and use the anonymised data indefinitely for statistical and analytical purposes without further obligation under this Policy.

Where a legal hold is in place — for example, in the context of ongoing litigation, a regulatory investigation, or a pending dispute — data that would otherwise be scheduled for deletion will be retained until the hold is formally lifted.

sq999 uses cookies and similar tracking technologies on the sq999 platform to ensure proper functioning, enhance your experience, and collect analytics data. The categories of cookies used by sq999 are as follows:

• Strictly necessary cookies: These cookies are essential for the sq999 platform to operate. They enable core functions such as session management, user authentication, security token validation, and the display of your account balance and game history. These cookies cannot be disabled without materially impairing your ability to use the platform.
• Functional cookies: These cookies remember your preferences — such as your preferred language, layout settings, and notification preferences — so that you do not need to re-enter them on each visit. Disabling functional cookies may reduce platform convenience but will not prevent basic use.
• Analytics cookies: These cookies collect aggregated, pseudonymised data about how players navigate the sq999 platform — such as pages visited, time spent on each section, and the sequence of clicks. This data is used by sq999 to identify usability issues, measure the effectiveness of new features, and improve the overall platform experience. Analytics cookies are optional and subject to your consent.
• Security cookies: These cookies are used by sq999's fraud detection and account security systems to identify suspicious access patterns, detect bot activity, and protect your account from unauthorised access.

You can manage your cookie preferences through the settings of the web browser you use to access sq999. Most modern browsers allow you to view, block, or delete cookies on a per-site basis. Please note that blocking all cookies, including strictly necessary cookies, may prevent you from logging in to or using the sq999 platform.

sq999 does not use third-party advertising cookies, retargeting cookies, or any cookies that track your browsing behaviour across websites other than sq999.io.

As a user of the sq999 platform, you have the following rights in relation to your personal data. To exercise any of these rights, please contact the sq999 Data Privacy team using the contact details in Section 15. sq999 will respond to all verified data subject requests within 30 calendar days.

• Right of access: You have the right to request a copy of the personal data that sq999 holds about you, along with information about how it is used and with whom it is shared.
• Right to rectification: You have the right to request that sq999 correct any inaccurate or incomplete personal data it holds about you. For basic profile data (name, address, contact details), you may update your information directly via your sq999 account dashboard.
• Right to erasure ("right to be forgotten"): You have the right to request that sq999 delete your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent (for consent-based processing), or where you object to processing on legitimate interest grounds and sq999 has no overriding legitimate interest. Note that this right is subject to sq999's legal obligations — data that must be retained for AML, regulatory, or legal claim purposes cannot be deleted prior to the end of the applicable retention period.
• Right to restriction of processing: You have the right to request that sq999 temporarily restrict the processing of your personal data while a dispute regarding its accuracy or the lawfulness of its processing is being resolved.
• Right to data portability: Where processing is based on your consent or on a contract with you, and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to object: You have the right to object at any time to processing of your personal data that is based on sq999's legitimate interests. sq999 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• Right to withdraw consent: Where sq999 processes your data on the basis of your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing that took place before the withdrawal.

The sq999 platform is intended exclusively for adults aged 21 years and above. sq999 does not knowingly collect personal data from anyone under the age of 21. Age verification is a mandatory step in the sq999 account lifecycle and is enforced as a condition of the first withdrawal.

If sq999 becomes aware that it has inadvertently collected personal data from a person under the age of 21, sq999 will immediately take the following steps:

• Suspend the relevant account pending a full review.
• Return any funds held in the account to the payment method from which they were deposited, to the extent technically practicable.
• Permanently delete all personal data associated with the account from sq999's systems as soon as the return of funds has been confirmed.

If you are a parent or guardian and believe that your child has accessed the sq999 platform or provided personal data to sq999, please contact the sq999 support team immediately at [email protected] so that we can take prompt remedial action.

sq999 strongly encourages parents and guardians to use internet filtering and parental control tools to restrict access to online gambling platforms by minors. A number of free and low-cost parental control solutions are available for all major device types and operating systems.

sq999 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• Encryption in transit: All data exchanged between your device and the sq999 platform is encrypted using TLS 1.2 or higher, with a 256-bit key. Connections using outdated protocols are rejected at the network boundary.
• Encryption at rest: Personal data and financial records stored on sq999 servers are encrypted at rest using AES-256 encryption. Encryption keys are managed through a dedicated key management system with strict access controls and regular key rotation.
• Access controls: Access to systems that hold personal data is restricted to authorised sq999 personnel on a strict need-to-know basis. All administrative access requires multi-factor authentication and is logged for audit purposes.
• Network security: sq999 infrastructure is protected by enterprise-grade firewalls, intrusion detection systems, and distributed denial-of-service (DDoS) mitigation services. Regular penetration testing is conducted by independent third-party security firms.
• Vulnerability management: sq999's engineering team conducts regular security reviews and applies security patches promptly. A responsible disclosure programme allows external security researchers to report vulnerabilities directly to sq999.
• Staff training: All sq999 personnel with access to personal data receive mandatory data protection and information security training upon joining and at regular intervals thereafter.
• Incident response: sq999 maintains a documented data breach response plan. In the event of a confirmed personal data breach that poses a risk to affected individuals, sq999 will notify relevant authorities and impacted users within the timeframes required by applicable law.

While sq999 takes all reasonable steps to protect your personal data, no system connected to the internet can be guaranteed to be entirely secure. You also have a role to play in keeping your account secure — please use a strong, unique password for your sq999 account, enable any two-factor authentication options made available on the platform, and never share your login credentials with any third party.

The sq999 platform may, from time to time, contain references to or integrations with third-party services, including payment gateways, identity verification portals, and game studio environments. When you navigate to or interact with a third-party service, you leave the sq999 platform and are subject to the privacy policy and terms of service of that third party, not this Policy.

sq999 has no control over, and accepts no responsibility for, the privacy practices or content of third-party websites or services. sq999 encourages you to review the privacy policies of any third-party service you access in connection with your use of the sq999 platform.

The inclusion of any third-party payment or gaming service on the sq999 platform does not constitute an endorsement by sq999 of that service's privacy practices beyond the contractual data protection obligations sq999 imposes on its partners as described in Section 6.

sq999 reserves the right to amend, update, or replace this Privacy Policy at any time. Changes may be made to reflect updates in applicable data protection legislation, changes to the sq999 platform or business model, guidance from regulatory authorities, or recommendations from data protection advisors.

When sq999 makes a material change to this Policy — meaning a change that significantly affects how your personal data is used or your rights in relation to it — sq999 will notify registered players by:

• Displaying a prominent notice on the sq999 platform for a period of not less than 14 days following the change;
• Sending an email notification to the address registered on your sq999 account, where you have a verified email address on file; and
• Updating the "Last Updated" date displayed at the top of this Privacy Policy page.

Non-material amendments — such as corrections of typographical errors, clarifications of existing practices that do not alter the substance of the Policy, or structural reformatting — may be made without prior notice. The current version of this Policy is always accessible at sq999.io/privacy-policy.

Your continued use of the sq999 platform following the effective date of any amendment to this Policy constitutes your acknowledgement and acceptance of the revised Privacy Policy. If you do not agree with the changes, you must cease using the sq999 platform and may request closure of your account by contacting sq999 support.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way in which sq999 processes your personal data, please contact the sq999 Data Privacy team using the details below. All privacy-related enquiries are handled by trained personnel and will receive a response within 5 business days.

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 via the sq999 platform
• Support hours: 24/7, Bangladesh Standard Time (BST, UTC+6)
• Response commitment: Initial acknowledgement within 24 hours; full response to data subject requests within 30 calendar days.

When submitting a data subject rights request, please include your registered sq999 username, a clear description of your request, and a copy of a valid identity document so that sq999 can verify your identity before releasing or modifying any personal data. This is a security measure designed to protect your data from unauthorised access by third parties.

sq999 is committed to resolving all privacy-related concerns directly and promptly. If you feel that sq999 has not adequately addressed your concern, you may seek further recourse through an independent data protection authority or a competent court of jurisdiction in accordance with applicable law.