clu99 Privacy Policy
At clu99, your privacy is treated with the same seriousness as your account security. This Privacy Policy explains in plain, formal English exactly what personal data we collect when you use the clu99 platform, why we collect it, how it is used, who it may be shared with, and what rights you hold over it. We encourage all players across Bangladesh to read this document carefully before registering.
Our Privacy Commitments
Six core principles that define how clu99 handles your personal data — every day, on every transaction.
clu99 collects only the personal data that is strictly necessary to deliver our services, comply with legal obligations, and prevent fraud. We do not gather data speculatively or for purposes unrelated to your use of the platform.
All data transmitted between your device and the clu99 platform is protected by 256-bit SSL/TLS encryption. Sensitive data stored on our servers — including payment details and identity documents — is encrypted at rest using AES-256 standards.
clu99 does not sell, rent, or trade your personal information to third-party advertisers, data brokers, or marketing companies. Your data is used solely for the purpose of operating and improving the clu99 platform and associated services.
You have the right to access, correct, or request deletion of the personal data clu99 holds about you. Requests can be submitted at any time via our support channel and will be processed within 30 days, subject to legal retention obligations.
Personal data is retained only for as long as necessary. Account data is kept for the duration of your active membership plus a post-closure period required for legal compliance. Data that is no longer required is securely deleted or anonymised.
In the unlikely event of a data breach that poses a risk to your rights and freedoms, clu99 will notify affected users promptly and take immediate remedial action. Our security team operates around the clock to detect and respond to threats.
This Privacy Policy ("Policy") is issued by clu99 ("we", "us", "our", "the Platform") and governs the collection, use, storage, disclosure, and protection of personal data relating to all registered users, prospective users, and visitors ("you", "your") of the clu99 website located at clu99.io and any associated mobile or web applications.
clu99 is committed to handling personal data with transparency, integrity, and security. We recognise that users of online betting and casino platforms entrust us with sensitive personal and financial information, and we take that responsibility seriously. This Policy sets out — in clear, formal English — precisely how that data is managed at every stage of its lifecycle.
By registering an account on clu99, depositing funds, placing bets, or otherwise using the platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree with any part of this Policy, you should not use the clu99 platform.
clu99 collects personal data in a number of categories, each of which serves a specific operational or legal purpose. The categories of personal data we collect include, but are not limited to, the following:
| Category | Examples | Purpose |
|---|---|---|
| Identity Data | Full name, date of birth, national ID number, passport number | Account registration and KYC verification |
| Contact Data | Email address, mobile phone number, residential address | Account communication, verification, support |
| Financial Data | bKash/Nagad/Rocket mobile wallet IDs, bank account numbers, transaction history | Processing deposits, withdrawals, and fraud prevention |
| Verification Documents | Copies of national ID (NID), passport, utility bills, selfies for liveness checks | Identity verification, age verification, KYC compliance |
| Account Activity Data | Betting history, casino game play history, deposit/withdrawal records, bonus usage | Service delivery, responsible gaming monitoring, dispute resolution |
| Technical Data | IP address, device type, browser type and version, operating system, session tokens | Security monitoring, fraud detection, platform optimisation |
| Usage Data | Pages visited, features accessed, time spent, click patterns | Platform analytics and user experience improvement |
| Communications Data | Live chat transcripts, support ticket contents, email correspondence | Customer service, dispute resolution, quality assurance |
We do not intentionally collect special categories of sensitive personal data (such as racial or ethnic origin, political opinions, religious beliefs, or health data) unless you voluntarily disclose such information in the context of a responsible gaming interaction (e.g., disclosing a gambling-related health concern to our support team), in which case it is processed solely for the purpose of providing appropriate assistance and safeguarding your welfare.
clu99 collects personal data through several distinct channels and mechanisms:
- Direct provision: Data you voluntarily provide when registering an account, completing your profile, submitting KYC documents, making deposits or withdrawal requests, contacting customer support, or participating in promotions.
- Automated technical collection: Data collected automatically when you access the clu99 website or application, including your IP address, device identifiers, session data, and browser characteristics. This collection occurs through server logs, cookies, and similar technologies.
- Third-party verification providers: Identity and age verification data received from third-party KYC and anti-money laundering (AML) service providers when you submit documents for account verification.
- Payment processors: Transaction confirmation data and fraud signals received from payment partners such as bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, Visa, and Mastercard during deposit and withdrawal processing.
- Game studios: Limited gameplay session data received from third-party game providers (such as Evolution Gaming, Pragmatic Play, Ezugi, and NetEnt) to enable game delivery, round reconciliation, and dispute resolution.
- Fraud and security tools: Risk signals and device fingerprinting data received from fraud prevention services used to protect the platform and its users from unauthorised access and financial crime.
clu99 processes your personal data only for clearly defined and legitimate purposes. The primary purposes for which personal data is processed on the clu99 platform are as follows:
- Account registration and management: Creating, maintaining, verifying, and administering your clu99 player account, including identity and age verification to ensure compliance with the 21+ age requirement.
- Service delivery: Enabling you to place bets on sports events including cricket (BPL, IPL, T20 World Cup), play live casino games, access slot titles, and use all other features offered by the clu99 platform.
- Payment processing: Processing your deposits and withdrawal requests via bKash, Nagad, Rocket, Upay, bank cards, and bank transfers, and maintaining accurate financial records of all transactions on your account.
- Regulatory compliance and KYC/AML: Meeting our obligations under applicable anti-money laundering, counter-terrorism financing, and know-your-customer regulations, which require us to verify user identities and monitor account activity for suspicious patterns.
- Fraud prevention and security: Detecting, investigating, and preventing fraud, money laundering, unauthorised account access, bonus abuse, and other forms of financial crime or platform manipulation.
- Responsible gaming: Monitoring account activity for signs of problem gambling, enforcing deposit limits, self-exclusion orders, and other responsible gaming measures requested by or applied to your account.
- Customer support: Responding to your enquiries, resolving disputes, processing complaints, and providing technical assistance through our 24/7 English-language support team.
- Marketing communications: Sending promotional offers, bonus notifications, and platform updates to users who have opted in to receive such communications. You may opt out at any time by contacting support.
- Platform improvement: Analysing aggregated usage data to improve the functionality, performance, and user experience of the clu99 platform.
clu99 processes personal data on the following legal bases, depending on the nature and purpose of each processing activity:
- Contractual necessity: Processing required to perform the contract between you and clu99 — including account registration, service delivery, payment processing, and account administration — is conducted on the basis that it is necessary to fulfil our contractual obligations to you.
- Legal obligation: Processing required to comply with applicable laws and regulations, including KYC/AML obligations, age verification requirements, and responses to lawful requests from regulatory or law enforcement authorities.
- Legitimate interests: Processing carried out to pursue the legitimate interests of clu99, such as fraud prevention, platform security, responsible gaming monitoring, and internal analytics — provided such interests are not overridden by your fundamental rights and freedoms.
- Consent: Processing activities for which you have provided explicit consent, such as receiving marketing communications. Where consent is the legal basis, you have the right to withdraw it at any time without affecting the lawfulness of prior processing.
clu99 does not sell your personal data to any third party. However, in order to deliver the services described in this Policy, it is necessary to share certain personal data with carefully selected third-party service providers and, in defined circumstances, with public authorities. The categories of recipients with whom your data may be shared are set out below:
- Payment service providers: bKash, Nagad, Rocket, Upay, Visa, Mastercard, Dutch-Bangla Bank, and BRAC Bank, for the purpose of processing your financial transactions. These providers are bound by their own privacy obligations and applicable financial regulations.
- Identity verification and KYC providers: Third-party providers who perform identity checks, document verification, and age verification on behalf of clu99 as part of our regulatory compliance obligations.
- Game studios: Licensed game providers including Evolution Gaming, Pragmatic Play, Ezugi, NetEnt, Microgaming, and Spribe, who receive limited player session data necessary to deliver game content and reconcile game outcomes.
- Fraud prevention and security services: Specialist providers engaged to detect and prevent fraudulent activity, unauthorised access, and financial crime on the platform.
- IT and infrastructure providers: Cloud hosting, database management, and software support providers who process data on behalf of clu99 under strict data processing agreements.
- Legal and regulatory authorities: clu99 may disclose personal data to law enforcement agencies, courts, regulators, or other governmental authorities where required by applicable law, court order, or to protect the legal rights of clu99 or third parties.
The operation of an international online platform such as clu99 may require your personal data to be transferred to, stored in, or processed in countries other than Bangladesh. This may occur when we engage service providers — such as cloud infrastructure vendors, KYC platforms, or game studios — that are domiciled or operate servers outside Bangladesh.
Wherever such transfers occur, clu99 ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that described in this Policy. These safeguards may include contractual obligations binding the recipient to adequate data protection standards, the use of certified secure data centres, and data minimisation measures that limit the scope of what is transferred.
If you have questions about the specific safeguards applicable to any particular international transfer of your personal data, please contact us at [email protected] and we will provide the relevant information to the extent permitted by law.
clu99 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The retention periods applicable to the main categories of personal data are summarised below:
| Data Category | Retention Period | Basis |
|---|---|---|
| Account and identity records | Duration of account + 5 years post-closure | Legal/regulatory obligation |
| Financial transaction records | 7 years from transaction date | AML and financial record-keeping obligations |
| KYC and verification documents | 5 years post account closure | Regulatory compliance |
| Customer support communications | 3 years from last interaction | Dispute resolution and quality assurance |
| Technical and usage data | 13 months from collection | Legitimate interests (security and analytics) |
| Marketing consent records | Until consent is withdrawn + 1 year | Consent accountability |
At the end of the applicable retention period, personal data is either securely deleted, anonymised (such that it can no longer be attributed to any identifiable individual), or archived in a restricted-access environment in accordance with legal requirements. Anonymised data may be retained indefinitely for aggregated statistical purposes.
As a user of the clu99 platform, you hold a number of rights in relation to your personal data. clu99 is committed to honouring these rights promptly and without undue restriction. Your rights include the following:
- Right of access: You have the right to request a copy of the personal data that clu99 holds about you, along with information about how it is processed.
- Right to rectification: If any personal data held by clu99 is inaccurate or incomplete, you have the right to request that it be corrected or updated.
- Right to erasure: In certain circumstances — for example, where the data is no longer necessary for the purpose for which it was collected — you may request that clu99 delete your personal data. This right is subject to legal retention requirements that may override erasure requests.
- Right to restrict processing: You may request that clu99 restrict the processing of your personal data in specific circumstances, such as where you contest its accuracy or object to its use.
- Right to data portability: Where processing is based on your consent or is necessary for the performance of a contract, you may request that your data be provided to you in a structured, commonly used, machine-readable format.
- Right to object: You have the right to object to the processing of your personal data where it is based on legitimate interests, including profiling. You also have an absolute right to object to processing of your data for direct marketing purposes.
- Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.
To exercise any of the above rights, please submit a written request to [email protected]. clu99 will respond within 30 calendar days of receiving your request. In complex cases, this period may be extended by a further 30 days, in which case you will be notified of the extension and the reasons for it. There is no charge for exercising your rights unless requests are manifestly unfounded or excessive, in which case a reasonable administrative fee may apply.
clu99 uses cookies and similar tracking technologies (including web beacons, pixel tags, and local storage) to operate and improve the platform. Cookies are small text files stored on your device that allow us to recognise your browser, maintain your session, and gather analytical data about how the platform is used.
- Essential cookies: Strictly necessary for the operation of the platform. These cookies enable core functions such as user authentication, session management, load balancing, and security. They cannot be disabled without impairing platform functionality.
- Analytical cookies: Used to collect anonymised data about how visitors interact with the platform — pages visited, time spent, error rates, and navigation paths. This data helps clu99 identify and resolve usability issues and improve the overall experience.
- Functional cookies: Remember your preferences and settings (such as language, display preferences, or responsible gaming tool configurations) so that you do not need to re-enter them on each visit.
- Security cookies: Support fraud detection and prevention mechanisms by identifying anomalous behaviour, flagging suspicious login patterns, and supporting multi-factor authentication flows.
You may manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the clu99 platform and your ability to access all features. Detailed cookie management instructions for major browsers (Chrome, Firefox, Safari, Edge) are available through those browsers' official help documentation.
clu99 implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security framework includes the following controls:
- Encryption in transit: All data exchanged between your browser or device and the clu99 platform is encrypted using TLS 1.2 or higher with 256-bit SSL certificates, preventing interception by third parties.
- Encryption at rest: Sensitive data fields stored in clu99's databases — including identity documents, financial records, and authentication credentials — are encrypted using AES-256 encryption.
- Access controls: Access to personal data within the clu99 organisation is strictly limited on a need-to-know basis. Staff who handle personal data undergo background screening and receive mandatory data protection training.
- Intrusion detection: clu99 operates continuous monitoring systems designed to detect and alert on suspicious access patterns, potential breaches, and anomalous activity in real time.
- Two-factor authentication (2FA): Account holders are strongly encouraged to enable 2FA for their clu99 accounts. Staff with access to administrative systems are required to use 2FA without exception.
- Regular security audits: clu99 engages third-party security specialists to conduct periodic penetration testing and security audits of the platform infrastructure and codebase.
While clu99 takes all reasonable steps to protect your data, no internet-based platform can guarantee absolute security against all possible threats. You are encouraged to use a strong, unique password for your clu99 account and to enable two-factor authentication to reduce the risk of unauthorised access.
clu99 is strictly an adult platform. Access to and use of all clu99 services is restricted to individuals who are aged 21 years or older. clu99 does not knowingly collect, process, or retain personal data belonging to individuals under the age of 21.
As part of the account registration process, all users are required to confirm their age and to submit identity documents that allow clu99 to verify that the minimum age requirement is met. Where an account is found to belong to an individual under the age of 21, it will be immediately suspended, all funds will be returned to the payment source used at the time of deposit, and all personal data associated with the account will be securely deleted in accordance with our data retention procedures.
If you are a parent or guardian and you believe that a minor has registered an account on clu99, please contact us immediately at [email protected] so that appropriate action can be taken without delay. We take the protection of minors from gambling-related harm with the utmost seriousness.
clu99 reserves the right to update or amend this Privacy Policy at any time. Changes may be required to reflect updates in applicable law, new platform features, changes in our data processing practices, or guidance from regulatory authorities.
When material changes are made to this Policy, clu99 will notify registered users by email to the address associated with their account, and/or by displaying a prominent notice on the platform at the point of login. The updated Policy will state the effective date of the revision at the top of the document.
We encourage you to review this Policy periodically to remain informed about how clu99 protects your personal data. Continued use of the platform following the publication of a revised Policy constitutes your acceptance of the changes.
If you have any questions, concerns, or requests relating to this Privacy Policy or to the processing of your personal data by clu99, please contact our Data Protection team. All privacy-related enquiries are handled by trained staff and are given priority treatment.
Data Protection contact email: [email protected]
Please note that the email address above is displayed as plain text only and is not a clickable link. For the fastest response, we recommend initiating your enquiry via the live chat function within your logged-in clu99 account, where our 24/7 English support team can assist you directly.
This Privacy Policy was last reviewed and updated on 1 January 2026 and supers edes all previous versions.
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