zoy9 Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how zoy9 ("we", "us", "our") collects, uses, stores, and protects the personal data of individuals ("you", "Player", "User") who access or use the zoy9 platform at https://zoy9.io and all associated services, applications, and features (collectively, the "Platform").

We are committed to handling your personal data in a manner that is transparent, lawful, and respectful of your privacy. By registering an account on the Platform, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein.

This Policy should be read alongside the zoy9 Terms & Conditions and our Responsible Gaming Policy. In the event of any conflict between this Policy and the Terms & Conditions in relation to privacy matters, the terms of this Policy shall prevail.

2 Who We Are

zoy9 is an online entertainment platform providing sports betting, live casino, slots, and related gaming products. The Platform is operated by zoy9 and is directed primarily at players residing in Bangladesh. Our official contact email for data-related enquiries is [email protected].

For the purposes of this Policy, zoy9 is the data controller in respect of personal data collected from users of the Platform. As data controller, we are responsible for determining the purposes and means by which your personal data is processed.

3 Data We Collect

zoy9 collects personal data across several categories depending on how you interact with the Platform. The table below outlines the main categories of data we may collect:

Category	Examples	Purpose
Identity Data	Full name, date of birth, gender, NID or passport number	Account registration, KYC verification, age verification
Contact Data	Email address, phone number, residential address, city (e.g., Dhaka, Chittagong)	Account communication, support, fraud alerts
Financial Data	bKash/Nagad/Rocket account numbers, Visa/Mastercard last-four digits, transaction history	Payment processing, withdrawal verification, AML compliance
Technical Data	IP address, browser type, device type, operating system, session tokens	Security monitoring, fraud prevention, platform optimisation
Usage Data	Pages visited, games played, betting history, session duration, click patterns	Personalisation, responsible gaming monitoring, product improvement
Communications Data	Live chat transcripts, support emails, survey responses	Customer service, dispute resolution, quality assurance
Marketing Preferences	Opt-in/opt-out status for emails, SMS, promotional notifications	Delivering relevant promotions only to consenting users

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 or by a regulatory compliance process, in which case we will inform you separately at the time of collection.

4 How We Collect Your Data

4.1 Directly From You

The majority of personal data we hold is provided directly by you at the time of registration, during the KYC verification process, when you make deposits or withdrawals, when you contact our support team, or when you respond to a survey or promotion. You are under no obligation to provide this data, but without it we may be unable to provide certain services or process transactions.

4.2 Automatically Through the Platform

When you access and use the Platform, we automatically collect certain technical and usage data through cookies, web beacons, server logs, and similar tracking technologies. This data is collected to ensure the Platform functions correctly, to protect against fraud, and to improve the overall user experience. See Section 8 for more detail on how we use cookies.

4.3 From Third Parties

In certain circumstances, we may receive data about you from third parties. This includes identity and fraud-check data from KYC verification service providers, payment confirmation data from mobile financial service operators (bKash, Nagad, Rocket, Upay) and card networks (Visa, Mastercard), and fraud-risk scores from anti-money laundering (AML) screening services. We process such third-party data only where we have a legitimate legal basis to do so.

5 Why We Use Your Data

zoy9 processes your personal data for the following purposes:

• Account Creation and Management: To register your account, verify your identity and age (21+ requirement), maintain your account settings, and process your requests.
• Payment Processing: To handle deposits and withdrawals via bKash, Nagad, Rocket, Upay, Visa, and Mastercard, and to maintain accurate financial records of all transactions.
• Legal and Regulatory Compliance: To comply with applicable anti-money laundering (AML) laws, Know Your Customer (KYC) obligations, and any other legal requirements that apply to our operations.
• Security and Fraud Prevention: To monitor for suspicious activity, detect and prevent fraud, protect against unauthorised access, and investigate potential breaches of our Terms & Conditions.
• Responsible Gaming: To monitor your gaming behaviour patterns and identify potential signs of problem gambling, enabling us to apply responsible gaming interventions such as deposit limit reminders and cooling-off prompts.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance through live chat and email.
• Marketing and Promotions: To send you relevant bonus offers, promotional updates, and news about new games — but only where you have given explicit consent to receive such communications.
• Platform Improvement: To analyse usage patterns, conduct testing, and develop new features that improve the overall experience for our player community in Bangladesh.

6 Legal Basis for Processing

Every instance of personal data processing by zoy9 rests on one or more of the following legal grounds:

• Contractual Necessity: Processing is required to fulfil our obligations under the Terms & Conditions you agreed to when registering your account — for example, processing your deposits, paying out winnings, and maintaining your account.
• Legal Obligation: Processing is required to comply with applicable laws — for example, KYC data collection to satisfy AML regulations, and transaction record-keeping for financial reporting purposes.
• Legitimate Interests: Processing is necessary for our legitimate business interests or those of a third party, provided those interests are not overridden by your rights — for example, fraud prevention, security monitoring, and general platform administration.
• Consent: Where you have given clear, freely-given, specific, and informed consent — for example, subscribing to promotional emails. You may withdraw this consent at any time without penalty to your account access.

7 Sharing Your Data

zoy9 does not sell, rent, or trade your personal data. We may share your data with carefully selected third parties strictly on a need-to-know basis for the following purposes:

7.1 Payment Service Providers

To process your deposits and withdrawals, we share necessary financial and identity data with our payment partners, including mobile financial service operators such as bKash, Nagad, Rocket, and Upay, and international card networks including Visa and Mastercard. These providers process your data under their own privacy policies and are contractually bound to protect it.

7.2 KYC and Fraud Prevention Providers

To comply with our KYC obligations and to prevent fraud and money laundering, we may share identity documents and related data with specialist third-party verification service providers. These providers are bound by strict confidentiality agreements and are prohibited from using your data for any purpose other than verification.

7.3 Technology and Hosting Providers

We use third-party technology providers for cloud hosting, data storage, platform infrastructure, and analytics. These providers act as data processors on our behalf and are contractually required to implement appropriate security measures and to process your data only on our documented instructions.

7.4 Game Software Providers

Certain technical data (such as anonymous session identifiers) may be shared with game software providers — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi — for the purpose of delivering their games on our Platform. These providers do not receive data that directly identifies you by name.

7.5 Legal and Regulatory Authorities

We may disclose your personal data to government authorities, law enforcement agencies, financial intelligence units, or courts where we are legally required to do so, or where we reasonably believe disclosure is necessary to protect our legal rights or to prevent harm to any person.

8 Cookies & Tracking Technologies

The zoy9 Platform uses cookies and similar tracking technologies to ensure the site functions correctly, to remember your preferences, and to analyse how players use our services. The main types of cookies we use are:

• Strictly Necessary Cookies: These are essential for the Platform to function. They enable core features such as maintaining your login session, processing transactions, and applying security measures. These cookies cannot be disabled.
• Functional Cookies: These remember your preferences (such as language settings and display options) to provide a more personalised experience. Disabling them may affect the functionality of certain features.
• Analytics Cookies: These help us understand how players interact with the Platform — which pages are visited most, how long sessions last, and where users navigate from. This data is aggregated and anonymised where possible.
• Security Cookies: These help detect and prevent fraudulent activity, protect against credential-stuffing attacks, and flag anomalous session behaviour in real time.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may impact your experience on the Platform. We do not use third-party advertising cookies or cross-site tracking pixels that follow you across unrelated websites.

9 Data Security

zoy9 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. Our key security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers.
• Encrypted storage of sensitive data at rest, including financial records and identity documents.
• Strict role-based access controls, ensuring that only authorised personnel can access personal data relevant to their specific function.
• Regular security audits, vulnerability assessments, and penetration testing by independent security specialists.
• Multi-factor authentication requirements for all internal systems that store or process personal data.
• Real-time intrusion detection and automated alerting systems to identify and respond to potential security incidents rapidly.

While we take all reasonable precautions to protect your data, no method of transmission over the internet or electronic storage is 100% secure. You also have a responsibility to keep your account credentials confidential and to notify us immediately at [email protected] if you suspect any unauthorised access to your account.

10 Data Retention

zoy9 retains personal data for no longer than is necessary to fulfil the purposes for which it was collected, or to comply with applicable legal and regulatory requirements. Our general retention guidelines are as follows:

• Active Account Data: Retained for the duration of your account's active status plus a period of 5 years following account closure, in line with standard financial record-keeping requirements.
• KYC and Identity Documents: Retained for a minimum of 5 years from the date of verification, as required by applicable AML regulations.
• Transaction Records: Retained for 5 years from the date of each transaction for financial audit and compliance purposes.
• Support Communications: Retained for 2 years from the date of the most recent interaction, unless the communication relates to an unresolved dispute or legal matter.
• Marketing Consent Records: Retained for as long as you hold an account, or until you withdraw consent, whichever comes first.
• Technical and Usage Data: Anonymised or deleted within 13 months of collection.

Upon expiry of the applicable retention period, personal data is securely deleted or permanently anonymised so that it can no longer be associated with any individual. You may request early deletion of your data (subject to our legal retention obligations) by contacting our support team.

11 Your Rights

As a user of the zoy9 Platform, you have the following rights in relation to your personal data. To exercise any of these rights, please contact us at [email protected]. We will respond to all valid requests within 30 days.

• Right of Access: You have the right to request a copy of the personal data we hold about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You can update most contact details directly within your account settings.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, or where you withdraw consent and there is no other lawful basis for processing. This right is subject to our legal data retention obligations.
• Right to Restrict Processing: You have the right to request that we limit the way we process your data in certain circumstances — for example, while the accuracy of your data is being verified following a rectification request.
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that we transmit it directly to another service provider where technically feasible.
• Right to Object: You have the right to object to the processing of your data where we rely on legitimate interests as our legal basis. You also have an unconditional right to object to direct marketing at any time.
• Rights Related to Automated Decision-Making: Where automated processing produces decisions that significantly affect you, you have the right to request human review of that decision.

12 Children & Minors

The zoy9 Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that an account has been registered by a person under 21, we will immediately suspend the account, initiate an investigation, and delete all associated personal data in accordance with applicable law.

If you are a parent or guardian and believe that a minor in your care has registered an account on zoy9, please contact us immediately at [email protected] and we will take prompt action to investigate and resolve the matter.

13 Third-Party Links

The zoy9 Platform may contain references to third-party brands, payment providers, and game software studios as part of our service descriptions. This Privacy Policy applies solely to data collected and processed by zoy9. It does not cover data practices of any third-party websites, applications, or services that may be referenced in our content.

We encourage you to review the privacy policies of any third-party services you use in connection with your zoy9 account — in particular, those of your chosen payment provider (e.g., bKash, Nagad, Rocket) — as their data practices are independent of ours and governed by their own policies.

14 Updates to This Policy

zoy9 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or the services we offer. When material changes are made, we will notify you by email (sent to your registered address) and by posting a prominent notice on the Platform no fewer than 7 days before the revised Policy takes effect.

The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. We encourage you to review this Policy periodically to stay informed about how we are protecting your data. Your continued use of the Platform after the effective date of a revised Policy constitutes your acceptance of the changes.

15 Contact & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the way zoy9 handles your personal data, please contact our Data Support team through the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 directly through the Platform
• Response Time: We aim to acknowledge all privacy-related enquiries within 24 hours and to provide a full response within 30 calendar days.

If you are not satisfied with our response to a privacy complaint, you have the right to escalate the matter to the relevant data protection authority in your jurisdiction. We take all privacy complaints seriously and will work in good faith to resolve any concerns raised by our players.