jaja9 Privacy Policy

1 Introduction

jaja9 ("we", "us", "our") operates an online betting and casino platform accessible at jaja9.io, primarily serving players located across Bangladesh including Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, and Cox's Bazar. In the course of providing our services, jaja9 collects and processes certain personal data relating to registered players and website visitors.

This Privacy Policy sets out the categories of personal data we collect, the purposes for which that data is processed, the legal basis on which we rely to process it, the third parties with whom it may be shared, the period for which it is retained, and the rights you hold in respect of your personal data. This Policy should be read in conjunction with the jaja9 Terms & Conditions and Responsible Gaming Policy, both of which are available on this website.

We are committed to handling your personal data with care, integrity, and in accordance with applicable data protection principles. jaja9 implements appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction.

2 Data We Collect

jaja9 collects personal data across several categories depending on your interaction with the platform. The following table summarises the key data types we process:

2.1 Special Category Data

jaja9 does not intentionally collect any special category personal data (such as health data, racial or ethnic origin, religious beliefs, or political opinions) unless you voluntarily disclose such information in the context of a responsible gaming request — for example, when requesting self-exclusion on mental health grounds. Any such data disclosed voluntarily will be processed solely for the purpose for which it was provided and will not be used for any other purpose.

3 How We Collect Data

jaja9 collects personal data through the following channels and mechanisms:

3.1 Direct Collection

The majority of personal data jaja9 holds about you is provided directly by you. This occurs when you complete the account registration form, submit KYC verification documents, deposit or withdraw funds, contact customer support, respond to promotional communications, or update your account preferences.

3.2 Automated Technical Collection

When you visit the jaja9 website or use our platform, certain technical data is collected automatically by our web servers and analytics systems. This includes your IP address, browser type, referring URL, pages visited, time on page, and device identifiers. This data is collected through server logs and, where applicable, cookies and similar tracking technologies (see Section 9 for full details of our cookie practices).

3.3 Payment Provider Data

When you initiate a deposit or withdrawal via bKash, Nagad, Rocket, or Upay, the relevant payment provider transmits confirmation and transaction reference data to jaja9. jaja9 does not have access to your full payment provider account credentials or PIN — only the transaction amount, reference number, and associated mobile number are shared with us for verification purposes.

3.4 Third-Party Identity Verification

During the KYC process, jaja9 may use third-party identity verification service providers to validate documents and confirm identity. These providers process your identity data on jaja9's behalf under strict contractual data protection obligations. The results of any verification checks are returned to jaja9 in summary form only.

4 Purposes of Processing

jaja9 processes your personal data for the following specific, documented purposes:

• Account Management: Creating, maintaining, and administering your jaja9 player account, including authentication and access control.
• Service Delivery: Processing your bets, game sessions, deposits, withdrawals, and bonus credits in accordance with the jaja9 Terms & Conditions.
• Identity Verification and KYC: Verifying your identity, age, and residential address to comply with applicable anti-money laundering and know-your-customer obligations before processing significant transactions.
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, money laundering, multiple account registrations, and other forms of abuse or unauthorised use of the jaja9 platform.
• Responsible Gaming: Monitoring your gameplay patterns to identify potential indicators of problem gambling, applying voluntary limits or restrictions requested by you, and administering self-exclusion arrangements.
• Customer Support: Responding to your queries, resolving disputes, processing complaints, and maintaining a record of communications for quality assurance and training purposes.
• Financial Record-Keeping: Maintaining accurate transaction records for accounting, audit, and regulatory compliance purposes.
• Marketing Communications: Sending you promotional offers, bonus notifications, game updates, and seasonal promotions (such as Eid, Pohela Boishakh, or BPL season offers) where you have opted in to receive such communications.
• Platform Improvement: Analysing aggregated and anonymised usage data to improve the performance, content, layout, and overall quality of the jaja9 platform.
• Legal Compliance: Meeting jaja9's obligations under applicable law and cooperating with any competent authority, court order, or lawful regulatory request.

5 Legal Basis for Processing

jaja9 processes your personal data on the following legal bases, depending on the specific purpose:

5.1 Contractual Necessity

Processing that is strictly necessary for the performance of the contract between you and jaja9 — including account creation, transaction processing, bet settlement, and customer support — is carried out on the basis of contractual necessity. Without this processing, jaja9 would be unable to provide the services described in the Terms & Conditions.

5.2 Legal Obligation

Certain processing activities are required to fulfil jaja9's legal obligations, including identity verification (KYC), anti-money laundering checks, and the retention of financial transaction records for audit purposes.

5.3 Legitimate Interests

jaja9 processes certain data on the basis of its legitimate interests, including fraud detection, platform security monitoring, responsible gaming oversight, and internal analytics for service improvement. Where we rely on legitimate interests, we have assessed that our interests are not overridden by your rights and freedoms as a data subject.

5.4 Consent

Where jaja9 processes your personal data for marketing communications or optional analytics features, we do so on the basis of your freely given, specific, informed, and unambiguous consent. You may withdraw your consent to marketing communications at any time by updating your account preferences or contacting [email protected]. Withdrawal of consent does not affect the lawfulness of any processing carried out before the withdrawal.

6 Sharing of Personal Data

jaja9 does not sell, rent, or trade your personal data to any third party for their independent marketing purposes. We share your personal data only in the limited circumstances described below:

6.1 Service Providers and Data Processors

jaja9 engages carefully selected third-party service providers to assist in delivering the platform and its underlying services. These include identity verification providers, payment processing partners (bKash, Nagad, Rocket, Upay), game content studios (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Ezugi, Spribe, and others), hosting and infrastructure providers, and customer support tools. All such providers act as data processors under binding contractual agreements that require them to handle your data solely on jaja9's instructions and to implement appropriate security measures.

6.2 Legal and Regulatory Disclosure

jaja9 may disclose your personal data to law enforcement agencies, regulatory authorities, courts, or other competent bodies where we are required to do so by applicable law, or where such disclosure is necessary to protect the legal rights of jaja9 or to prevent serious harm to any person.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of jaja9's business, your personal data may be transferred to the acquiring entity as part of that transaction. In such circumstances, jaja9 will take reasonable steps to ensure that the acquiring entity honours the commitments set out in this Privacy Policy with respect to your personal data.

6.4 Aggregated Data

jaja9 may share aggregated and fully anonymised statistical data (which cannot be used to identify any individual player) with business partners, advertisers, or for publication in industry reports. No individual-level personal data is included in any such disclosures.

7 Data Retention

jaja9 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention periods apply:

At the end of the applicable retention period, personal data is securely deleted or anonymised in accordance with our internal data destruction procedures. Anonymised data may be retained indefinitely for statistical analysis.

8 Data Security

jaja9 takes the security of your personal data seriously and implements a range of technical and organisational safeguards designed to protect your information against unauthorised access, accidental loss, alteration, or disclosure. Our security measures include:

• SSL/TLS Encryption: All data transmitted between your device and the jaja9 platform is encrypted using industry-standard SSL/TLS protocols, ensuring that your personal and financial information cannot be intercepted in transit.
• Hashed Password Storage: Account passwords are never stored in plain text. jaja9 uses one-way cryptographic hashing algorithms to store credential data securely.
• Access Controls: Access to personal data held by jaja9 is restricted to authorised personnel on a strictly need-to-know basis. All staff members with access to personal data are bound by confidentiality obligations.
• Infrastructure Security: jaja9's platform infrastructure is hosted in secure data centres with physical access controls, redundant connectivity, and continuous availability monitoring.
• Regular Security Assessments: jaja9 conducts periodic internal reviews of its data security practices and engages third-party specialists to carry out security testing on the platform.

9 Cookies and Tracking Technologies

9.1 What Are Cookies?

Cookies are small text files placed on your device by websites you visit. They are widely used to make websites function efficiently, to remember user preferences, and to provide analytical information to site operators. jaja9 uses cookies and similar technologies (such as web beacons and local storage) to deliver and improve the jaja9 platform experience.

9.2 Categories of Cookies Used by jaja9

9.3 Managing Cookies

You may control or disable cookies through your browser settings. Most modern browsers allow you to refuse all or certain categories of cookies, or to delete cookies already stored on your device. Please note that disabling strictly necessary cookies may affect the functionality of the jaja9 platform and prevent you from accessing certain features, including account login and transaction processing.

10 Your Privacy Rights

As a jaja9 player, you hold the following rights in respect of your personal data. You may exercise any of these rights at any time by contacting our support team at [email protected] with your registered account details and a clear description of your request.

jaja9 will respond to all verifiable privacy rights requests within 30 days of receipt. Where a request is complex or involves a large volume of data, we may extend this period by a further 60 days and will notify you accordingly. jaja9 will not charge a fee for handling privacy rights requests unless they are manifestly unfounded or excessive.

11 Protection of Minors

The jaja9 platform is strictly intended for adults aged 21 years and above. jaja9 does not knowingly collect personal data from individuals under the age of 21. If you are under 21, you must not register an account or use the jaja9 platform in any way.

If jaja9 becomes aware or has reason to believe that personal data has been collected from a person under the age of 21 — whether as a result of a KYC check, a complaint, or any other means — the relevant account will be immediately suspended, all associated funds will be held pending investigation, and the data collected will be securely deleted as soon as the investigation is concluded and any applicable legal hold period has passed.

Parents, guardians, and other responsible adults are encouraged to make use of device-level parental control tools to prevent minors from accessing gambling websites. If you believe a minor has registered on the jaja9 platform, please contact us immediately at [email protected].

12 International Data Transfers

The jaja9 platform primarily serves players in Bangladesh, and we aim to store and process the majority of player data within server infrastructure located in the Asia-Pacific region. However, certain service providers engaged by jaja9 — particularly game content studios (such as Pragmatic Play, Evolution Gaming, Microgaming, and NetEnt) and third-party infrastructure providers — may process data in jurisdictions outside Bangladesh.

Where personal data is transferred outside Bangladesh, jaja9 takes steps to ensure that an appropriate level of protection is applied to that data, including through the use of standard contractual clauses, data processing agreements, and transfers only to providers operating in jurisdictions with recognised data protection standards. If you have questions about international data transfers, please contact [email protected].

13 Changes to This Privacy Policy

jaja9 reserves the right to update, revise, or replace this Privacy Policy at any time. When material changes are made to this Policy, we will notify registered players by email or via a prominent notice on the jaja9 platform prior to the changes taking effect. The effective date shown at the top of this page will be updated to reflect the date of the most recent revision.

Your continued use of the jaja9 platform after the revised Privacy Policy takes effect constitutes your acknowledgement of and consent to the updated terms. If you do not agree with the revised Policy, you must cease using the platform and contact [email protected] to request account closure and deletion of your personal data, subject to applicable legal retention obligations.

We encourage you to review this Privacy Policy periodically to stay informed about how jaja9 protects your personal information. Previous versions of this Policy are available on request by contacting our support team.

14 Contact and Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the way in which jaja9 handles your personal data, please contact our dedicated privacy support team. Our team is available 24 hours a day, 7 days a week, including Eid and all Bangladeshi public holidays.

Privacy support email: [email protected]

jaja9 aims to resolve all privacy-related enquiries promptly and in a transparent manner. We will acknowledge receipt of your query within 2 business days and provide a substantive response within 30 calendar days. If we require additional time to address a complex request, we will inform you of the extended timeline in writing.