Privacy Policy — How ja9 Protects Your Data

1. Personal Data We Collect

ja9 collects personal data from several sources depending on how you interact with the Platform. The categories of data we collect are as follows:

1.1 Data You Provide Directly

• Registration data: Full name, date of birth, email address, phone number, and preferred currency (BDT).
• Verification documents: National Identity Card (NID), passport, driving licence, or other government-issued identification provided during the KYC (Know Your Customer) process.
• Payment data: Mobile banking account numbers (bKash, Nagad, Rocket, Upay), card details (Visa, Mastercard), and transaction records. Full card numbers are never stored on our servers — they are processed securely via our payment partners.
• Communications: Any messages, support tickets, feedback, or complaints you send to the ja9 support team.
• Responsible gaming requests: Self-exclusion requests, deposit limit preferences, and session time-out settings submitted by you.

1.2 Data Collected Automatically

• Technical data: IP address, device type, operating system, browser type and version, and screen resolution.
• Usage data: Pages visited, games played, bets placed, session duration, login timestamps, and navigation patterns within the Platform.
• Location data: Approximate geographic location derived from your IP address, used to verify access eligibility and comply with regional requirements.
• Cookie data: Session identifiers, preference tokens, and analytics tags as described in Section 7 of this Policy.

1.3 Data from Third Parties

We may receive supplementary data from third-party identity verification services, fraud detection providers, and payment processors. This data is used solely to verify your identity, confirm payment ownership, and detect potentially fraudulent activity. ja9 does not purchase marketing data or consumer profiles from data brokers.

2. How We Use Your Personal Data

ja9 processes your personal data only for the purposes described below. We rely on the following legal bases for processing:

3. Data Sharing & Third-Party Processors

ja9 operates with a network of trusted third-party service providers who assist us in running the Platform. We share only the minimum data necessary for each provider to perform their specific function. Our key third-party categories are:

• Payment Processors: bKash, Nagad, Rocket, Upay, Visa, and Mastercard receive transaction data necessary to process your deposits and withdrawals. Each processor operates under their own independently maintained privacy policy and security standards.
• Game Studios: Providers such as Evolution Gaming, Pragmatic Play, Ezugi, Spribe, NetEnt, and Microgaming may receive session identifiers and anonymised player data necessary to deliver their game content. They do not receive your full personal profile.
• Identity Verification Services: Third-party KYC partners receive copies of verification documents submitted by players for the purpose of age and identity confirmation. These documents are processed under strict confidentiality agreements.
• Fraud Detection Providers: Automated fraud screening services may receive IP addresses, device fingerprints, and transaction metadata to flag potentially suspicious activity.
• Analytics Providers: Anonymised, aggregated usage data may be shared with analytics platforms to help us understand Platform performance. No personally identifiable information is included in these datasets.
• Legal Authorities: In cases where we are legally required to do so, ja9 may disclose personal data to law enforcement agencies, regulatory bodies, or courts of competent jurisdiction. We will notify affected players where we are legally permitted to do so.

All third-party processors are required to handle your data solely as directed by ja9, maintain appropriate security standards, and refrain from using your data for their own purposes.

4. Data Retention

ja9 retains personal data only for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable law. Our general retention periods are as follows:

• Active accounts: Personal data is retained for the full duration of your account relationship with ja9, plus a minimum of five (5) years following account closure to satisfy AML and financial record-keeping obligations.
• Identity verification documents: Copies of NID, passport, or other verification documents are retained for a minimum of five (5) years following account closure.
• Transaction records: Full transaction histories in BDT are retained for a minimum of five (5) years for financial compliance purposes.
• Support communications: Records of customer support interactions are retained for three (3) years following resolution of the relevant issue.
• Cookies and session data: Session cookies expire when you close your browser. Persistent analytics cookies have a maximum lifespan of twelve (12) months from placement.

When retention periods expire, personal data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual.

5. Your Data Rights

ja9 respects your rights in relation to your personal data. You may exercise the following rights at any time by contacting us at [email protected] with the subject line "Data Rights Request":

• Right of Access: You may request a copy of the personal data ja9 holds about you. We will provide this information within thirty (30) days of receiving a valid request.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it without undue delay.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations. Note that data subject to AML or KYC retention requirements cannot be deleted until those obligations are satisfied.
• Right to Restriction: You may request that we restrict processing of your personal data in certain circumstances — for example, while a dispute about its accuracy is being resolved.
• Right to Object: You may object to processing based on our legitimate interests. We will assess your objection and cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Data Portability: You may request that we provide your personal data in a structured, commonly used, machine-readable format where technically feasible.

ja9 will never penalise you for exercising your data rights. However, in some cases, exercising certain rights (such as the right to erasure) may result in the closure of your account if the data in question is necessary to maintain it.

6. International Data Transfers

ja9 serves players primarily across Bangladesh, including Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, and Cox's Bazar. Some of our third-party service providers — including game studios and fraud prevention partners — operate from outside Bangladesh. Where personal data is transferred internationally, ja9 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that described in this Policy.

These safeguards include contractual data processing agreements that impose obligations on the recipient consistent with applicable data protection standards, and technical security measures commensurate with the sensitivity of the data transferred.

7. Cookies & Tracking Technologies

ja9 uses cookies — small text files stored on your device — and similar technologies to operate and improve the Platform. We use the following categories of cookies:

7.1 Essential Cookies

These cookies are strictly necessary for the Platform to function. They maintain your login session, remember your language preference, and enable secure financial transactions. You cannot opt out of essential cookies while continuing to use ja9.

7.2 Analytics Cookies

Analytics cookies help us understand how players use ja9 — which pages are visited most, where users encounter difficulties, and how performance varies across devices. Data collected by analytics cookies is aggregated and anonymised before analysis. You may disable analytics cookies via your browser settings.

7.3 Preference Cookies

Preference cookies remember your account settings, game display preferences, and notification choices so that your experience remains consistent between visits. Disabling these cookies may affect the convenience of your experience on the Platform but will not prevent access.

7.4 Managing Cookies

Most modern browsers allow you to view, delete, and block cookies through the browser's settings or privacy controls. Please note that blocking essential cookies will prevent you from logging in or completing transactions on ja9. For guidance on managing cookies in your specific browser, refer to your browser's help documentation.

8. Children & Minors

ja9 is strictly an adult platform. We do not knowingly collect personal data from individuals under the age of 21. If we discover that a player account has been registered by a person under 21, we will immediately close the account, return any deposited real-money funds via the original payment method, and permanently delete all personal data associated with that account.

If you believe that a minor has registered on ja9, please contact [email protected] immediately with as much relevant detail as possible. We will investigate and act promptly. Parents and guardians are encouraged to use parental control software to prevent underage access to online gambling platforms.

9. Changes to This Privacy Policy

ja9 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or Platform functionality. Where changes are material, we will notify you via the email address registered on your account or via a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date displayed at the top of this page indicates when the Policy was most recently revised. We encourage you to review this Policy periodically. Your continued use of ja9 after the effective date of any revision constitutes your acceptance of the updated Policy.

10. Contact Our Data Team

If you have any questions, concerns, or requests relating to this Privacy Policy or how ja9 handles your personal data, please reach out using the contact details below. We are committed to responding to all privacy-related enquiries within ten (10) business days.

• Email: [email protected] (plain text — not a clickable link)
• Subject Line for Data Requests: "Data Rights Request" or "Privacy Policy Enquiry"
• Support Hours: 24 hours a day, 7 days a week, Bangladesh Standard Time (BST, UTC+6)

For responsible gaming-related data requests — such as accessing records of your self-exclusion history or deposit limit settings — please use the subject line "Responsible Gaming Data Request" when contacting support.