Privacy Policy 99ply —
Your Data, Our Responsibility

99ply ("we", "Platform") takes the privacy of every member seriously. This Privacy Policy explains our data collection and management practices when you use the website, mobile app, or any digital services provided by 99ply.

We are committed to ensuring that all information you provide to us is handled with the utmost integrity, stored securely, and used only for legitimate and transparent purposes. Your trust is the foundation of our relationship, and we will never take that responsibility lightly.

This Policy applies to all users of the 99ply platform, including website visitors, registered members, and former members whose accounts have been closed. If you are under 18 years of age, you are not permitted to use this platform and this Privacy Policy does not apply to you.

We collect information from you through several different channels. The following are the main categories of information we collect and why they are required:

The information we collect is used responsibly and limited to the following purposes only:

• Account Management: Creating, verifying, and maintaining your member account securely, including processing registration and login verification.
• Financial Processing: Processing deposits, withdrawals, and transaction history accurately and securely through integrated payment channels.
• Customer Support: Providing effective assistance when you contact our support team, including verifying your identity before taking any action on your account.
• Fraud Prevention: Identifying and preventing fraudulent activity, money laundering, and other security threats that could compromise your account.
• Regulatory Compliance: Fulfilling legal obligations and reporting requirements to the relevant authorities when required by law.
• Platform Improvements: Analyzing usage patterns in aggregate (not at an individual level) to improve user experience, platform speed, and service quality.
• Important Communications: Sending account-related notifications, security updates, and promotional information (subject to your preferences).
• Responsible Gaming: Monitoring gaming patterns to identify early signs of problem gambling and providing appropriate assistance when needed.

99ply does not sell, rent, or transfer your personal data to third parties for commercial purposes. However, in the following limited situations, we may share your information:

• Payment Service Providers: Required financial information is shared with authorized payment providers (such as banks and e-wallet providers) solely for the purpose of processing your transactions.
• Regulatory Authority: We fully comply with lawful requests from law enforcement agencies or regulatory authorities with valid jurisdiction.
• Technology Partners: Third-party technical service providers that assist us in operating the platform (such as cloud and security services) are bound by strict confidentiality agreements and may only access the minimum data necessary.
• Identity Verification: Trusted third-party KYC verification services are used to verify member identities, and information shared is limited to what is required for verification purposes only.

We continuously invest in security technologies and processes to protect your personal data. Key measures we have implemented include:

• 256-bit SSL/TLS encryption for all data communications between your browser and our servers.
• Passwords are stored using a secure one-way hashing algorithm — we cannot view your password ourselves.
• Two-factor authentication (2FA) is available for all member accounts as an additional layer of protection.
• Regular security scans and penetration testing conducted by independent security experts.
• Strict internal access controls — only authorized personnel may access member data within the scope of their responsibilities.
• 24/7 activity log monitoring to detect and respond to threats promptly.
• A security incident response plan is in place to ensure you are notified in the event of any data breach involving your information.

99ply uses cookies and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device when you visit our website.

Types of cookies we use:

• Essential Cookies: Required for core platform functions such as login session verification and security. These cookies cannot be disabled.
• Performance Cookies: Collecting aggregated and anonymized information about how visitors use our website to help us improve the platform.
• Functional Cookies: Storing your preferences such as language and display settings to deliver a more personalized experience.
• Security Cookies: Helping us detect suspicious activity and protect your account from unauthorized access.

You can manage or delete cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality and user experience of the 99ply platform.

As a 99ply member, you have the following rights regarding your personal data, in accordance with the Personal Data Protection Act 2010:

To exercise any of the above rights, please contact our support team. We will process your request within 14 working days and may require identity verification before any action is taken.

We retain your personal data for as long as necessary to fulfill the purposes stated in this Privacy Policy, or for as long as required by applicable law.

• Active Account Data: Retained for as long as your account remains active and for a reasonable period after account closure.
• Financial Transaction Records: Retained for a minimum of 7 years in accordance with financial and tax legal requirements.
• KYC Documents: Retained for the period specified by the relevant regulatory body, typically no less than 5 years after the business relationship ends.
• Security Logs: Retained for 12 months for security incident investigation purposes if required.
• Support Communication Data: Customer support interaction records are retained for 3 years for quality assurance and reference purposes.

When data is no longer needed and there is no legal obligation to retain it, we will delete or destroy that data in a secure and irreversible manner.

99ply reserves the right to update or modify this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or platform improvements. When material changes are made, we will:

• Displaying a clear notice on the platform's home page before changes take effect.
• Sending a notification to your registered email address at least 7 days before the effective date of any significant changes.
• Updating the "Last Updated" date at the top of this document.

Continued use of the 99ply platform after any Privacy Policy changes take effect will be considered your acceptance of the updated policy. We encourage you to review this page periodically to stay informed about how we protect your information.

If you have any questions, concerns, or complaints regarding this Privacy Policy or how we handle your personal data, we encourage you to reach out to us. Our data protection team is ready to assist you.

You can reach us via:

• Live Chat: Available 24/7 within the 99ply platform for immediate responses.
• Email: [email protected] — we aim to respond within 1–2 working days.
• FAQ Page: Visit FAQ page for answers to common questions about privacy and account security.

Effective date: 1 January 2026. This Privacy Policy forms part of Terms and Conditions 99ply and should be read together.