Privacy Policy — How 90jl Protects Your Personal Data

1. Introduction and Scope

This Privacy Policy ("Policy") describes how 90jl ("90jl", "we", "us", "our") collects, uses, stores, shares, and protects personal data in connection with the 90jl online casino and sports betting platform available at https://90jl.io and any associated subdomains, mobile-optimised pages, or related services (collectively, "the Platform").

This Policy applies to all individuals who interact with the Platform, including visitors who browse without registering, registered account holders, and former account holders whose data we may be required to retain for legal or compliance purposes. By accessing or using the Platform, you acknowledge that you have read and understood this Policy.

The 90jl platform is designed and marketed for use by adults aged 21 years and above, based in Bangladesh. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a minor, we will take immediate steps to delete that data and close the associated account.

2. Data Controller Information

For the purposes of this Policy, 90jl acts as the data controller in respect of personal data collected through the Platform. This means that 90jl determines the purposes and means by which your personal data is processed. All data-related queries, requests, and complaints should be directed to:

• Support Email: [email protected]
• Platform URL: https://90jl.io
• Support Hours: 24/7, Bangladesh Standard Time (BST, UTC+6)

3. Categories of Personal Data Collected

Depending on how you interact with the Platform, 90jl may collect and process the following categories of personal data:

Category	Examples	When Collected
Identity Data	Full name, date of birth, national ID number, passport number	Registration and KYC verification
Contact Data	Email address, mobile phone number, residential address (city, district)	Registration and Account updates
Financial Data	bKash/Nagad/Rocket wallet numbers, bank account details, transaction history, deposit and withdrawal records	Deposit, withdrawal, and payment processing
Technical Data	IP address, device type, browser type and version, operating system, screen resolution, session timestamps	Automatically on each visit
Usage Data	Pages visited, games played, wagers placed, bet amounts, session duration, feature interactions	Automatically during Platform use
Communications Data	Support tickets, live chat transcripts, emails sent to [email protected]	When you contact support
Verification Documents	Scanned copies of national ID, passport, utility bills, or bank statements submitted for KYC	Identity verification process

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data, or health information unless specifically required by law. We do not process credit card numbers directly — payment card transactions are handled by certified third-party payment processors.

4. How We Collect Your Data

90jl collects personal data through the following channels:

• Direct Submission: Data you provide when creating an Account, completing KYC verification, initiating a deposit or withdrawal, or contacting our support team.
• Automated Collection: Technical and usage data collected automatically through cookies, session identifiers, log files, and similar tracking technologies when you access and navigate the Platform.
• Payment Processors: Transaction confirmation and status data provided by bKash, Nagad, Rocket, Upay, and our banking partners following completion of a deposit or withdrawal.
• Identity Verification Providers: Data returned by third-party KYC and identity verification services following the submission of your identity documents.
• Fraud and Security Systems: Data generated by our internal fraud detection and risk management systems during your use of the Platform.

5. Legal Bases for Processing

90jl processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform the contract between you and 90jl — including operating your Account, processing deposits and withdrawals, and delivering gaming services.
• Legal Obligation: Processing required to comply with applicable legal and regulatory obligations, including anti-money-laundering (AML) requirements, Know Your Customer (KYC) procedures, and record-keeping obligations.
• Legitimate Interests: Processing carried out for the purposes of fraud detection, platform security, improving our services, and understanding how players interact with the Platform — provided these interests are not overridden by your own privacy interests.
• Consent: Processing based on your explicit consent, including sending marketing communications and placing non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6. How We Use Your Personal Data

The personal data we collect is used strictly for the following purposes:

• Creating, managing, and maintaining your 90jl Account.
• Verifying your identity and age (21+) in compliance with KYC requirements.
• Processing deposits, withdrawals, and bet settlements in BDT via approved payment channels.
• Detecting, investigating, and preventing fraud, money laundering, collusion, and other prohibited conduct.
• Providing customer support and resolving disputes, complaints, and technical issues.
• Sending account-related transactional communications — including deposit confirmations, withdrawal notifications, and security alerts — to your registered email address.
• Sending promotional and marketing communications about 90jl offers, where you have provided explicit consent and have not subsequently opted out.
• Conducting responsible gaming interventions, including applying deposit limits, time-out periods, or self-exclusion where triggered by player behaviour or player request.
• Analysing aggregate usage patterns to improve the Platform's performance, features, and user experience.
• Complying with applicable legal, regulatory, and audit obligations.

7. Cookies and Tracking Technologies

90jl uses cookies and similar tracking technologies to operate the Platform effectively, ensure security, and understand how players use our services. The categories of cookies we use are as follows:

Cookie Type	Purpose	Consent Required
Strictly Necessary	Session authentication, security tokens, load balancing, and fraud prevention. Without these cookies the Platform cannot function correctly.	No — these are essential
Functional	Remembering your language preferences, display settings, and session state between visits.	No — functional operational use
Analytics	Understanding page visit patterns, session durations, feature usage, and error rates. Data is aggregated and anonymised before analysis.	Yes — requires consent
Marketing	Tracking the effectiveness of promotional campaigns and, where consented, delivering personalised offers.	Yes — requires consent

You may manage your cookie preferences through your browser settings. Disabling strictly necessary or functional cookies may impair your ability to use certain features of the Platform. We do not use third-party advertising networks or cross-site tracking cookies.

8. Data Sharing and Third Parties

90jl does not sell, rent, or commercially share your personal data. We share data with third parties only in the following limited circumstances, and only to the minimum extent necessary:

• Payment Processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, and Sonali Bank receive the transaction data required to process deposits and withdrawals in BDT.
• Identity Verification Providers: KYC service providers receive copies of identity documents submitted by players for the purpose of age and identity verification only.
• Game Providers: Providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi may receive a pseudonymous session token to enable game delivery. They do not receive your full identity or financial data.
• Fraud and Security Partners: Specialist fraud prevention and risk management service providers may receive technical data (such as IP addresses and device fingerprints) to assist in detecting and preventing prohibited conduct.
• Legal and Regulatory Authorities: Where required by applicable law, court order, or regulatory obligation, we may disclose personal data to law enforcement agencies or other competent authorities. We will notify you of such disclosure where legally permitted to do so.
• Professional Advisers: Lawyers, auditors, and insurers who provide professional services to 90jl may have access to personal data on a need-to-know basis, subject to professional confidentiality obligations.

9. Your Data Rights

As described in the "Data Rights" section above, you hold the right of access, rectification, erasure, restriction, portability, and objection in respect of your personal data. To exercise any of these rights, please submit a written request to [email protected] from your registered email address. Please include:

• Your full name and Account username.
• A clear description of the right you wish to exercise and the specific data or processing activity to which your request relates.
• Any relevant context or reference numbers (e.g., transaction IDs, support ticket numbers) that may help us locate the relevant data.

We will acknowledge your request within 48 hours and provide a substantive response within 30 calendar days. In complex cases where more time is required, we will notify you within the initial 30-day window and provide a revised timeline, which will not exceed a further 60 days.

Please note that the right to erasure is subject to certain limitations. We are required to retain specific categories of financial and identity data for a minimum of five (5) years following account closure to comply with anti-money-laundering obligations. Data retained solely for compliance purposes is segregated, access-restricted, and deleted promptly upon expiry of the mandatory retention period.

10. Data Retention

90jl retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following retention periods apply as a general guide:

Data Category	Retention Period	Basis
Account and identity data	Duration of Account + 5 years post-closure	Legal / AML compliance
Financial transaction records	Duration of Account + 5 years post-closure	Legal / AML compliance
KYC verification documents	Duration of Account + 5 years post-closure	Legal / AML compliance
Support communications	3 years from last communication	Legitimate interests / dispute resolution
Technical / log data	12 months rolling	Security and fraud prevention
Marketing consent records	Until consent withdrawn + 3 years	Legal compliance
Anonymised analytics data	Indefinitely (non-personal)	Service improvement

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised using industry-standard data destruction protocols.

11. Data Security

90jl implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Transport Layer Security (TLS 1.3) encryption for all data transmitted between your device and the 90jl platform.
• AES-256 encryption at rest for all stored personal and financial data.
• Role-based access controls (RBAC) ensuring that only authorised personnel can access personal data, and only to the extent required for their specific role.
• Comprehensive audit logging of all access to personal data stores, with anomaly detection and real-time alerting.
• Regular penetration testing and vulnerability assessments conducted by qualified third-party security specialists.
• Two-factor authentication (2FA) enforced for all administrative access to systems holding personal data.
• Staff training on data protection responsibilities conducted at onboarding and on an annual refresher basis.
• A documented incident response procedure enabling rapid containment and notification in the event of a data breach.

In the event of a personal data breach that is likely to result in a risk to your rights, 90jl will notify affected players by email to their registered address without undue delay after becoming aware of the breach.

12. Children and Minors

The 90jl platform is strictly restricted to adults aged 21 years and above. We do not knowingly collect, store, or process personal data relating to any individual under the age of 21. Age verification is performed as part of the account registration and KYC process. If a parent or guardian believes that a minor has registered on the Platform or submitted personal data, they should contact us immediately at [email protected]. We will investigate promptly and, where confirmed, delete all data associated with the minor's account and close the account without delay.

13. Changes to This Privacy Policy

90jl reserves the right to update or amend this Privacy Policy at any time. Where changes are material — meaning they affect how we use your personal data in a way that is less favourable to you, or introduce new categories of data collection — we will notify registered players by email to their registered address not less than fourteen (14) days before the revised Policy takes effect. For non-material clarifications and corrections, the updated Policy will be published on this page with a revised "Last Updated" date.

Continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. We recommend checking this page periodically to stay informed of the current terms.

14. Contact and Complaints

For all privacy-related queries, data subject requests, or complaints relating to how 90jl handles your personal data, please contact our support team using the details below:

• Support Email: [email protected] (plain text — not a clickable link)
• Support Hours: 24/7, Bangladesh Standard Time (BST, UTC+6)
• Platform URL: https://90jl.io

We take all privacy complaints seriously. If you submit a complaint to our support team and remain dissatisfied with our response after following our internal resolution process, you may seek further recourse through appropriate channels available in your jurisdiction.