Privacy Policy — jae9

Introduction

jae9 operates as an offshore online casino and sports betting platform serving players in Bangladesh and other eligible markets. As an operator handling real-money financial transactions and sensitive personal information, jae9 recognises that data privacy is not merely a regulatory obligation — it is a fundamental component of the trust relationship between the platform and every player who registers an account.

This Policy has been drafted in plain English to ensure that players in Bangladesh fully understand what data jae9 collects, the specific purposes for which that data is used, and the safeguards that are in place to protect it. We do not use technical or legal language unnecessarily. Where legal terms are required, they are explained in context.

This Policy should be read alongside the jae9 Terms & Conditions and Responsible Gaming policy, both of which are incorporated by reference. Together, these three documents constitute the complete agreement between jae9 and each registered player regarding the use of the platform and the handling of personal data.

jae9 reserves the right to amend this Policy at any time. The "Last updated" date at the top of this page will reflect the date of the most recent revision. Material changes will be communicated to registered players via email. Continued use of jae9 following the effective date of any amendment constitutes acceptance of the revised Policy.

Data Controller

For the purposes of this Policy, jae9 is the data controller responsible for the personal data of registered players and website visitors. As the data controller, jae9 determines the purposes and means of processing personal data collected through jae9.io and its associated services.

All data privacy enquiries, access requests, correction requests and deletion requests should be directed to the jae9 data privacy team using the contact details set out in Section 16 of this Policy. jae9 aims to respond to all data-related correspondence within 30 calendar days of receipt.

Data We Collect

jae9 collects personal data only to the extent necessary to operate a secure, compliant and fully functional online gambling platform. The categories of data we collect include the following:

jae9 does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, biometric data (beyond liveness checks for KYC purposes), or health data, unless such data is voluntarily disclosed by the player in the context of a responsible gaming self-exclusion request or support communication.

How We Collect Data

jae9 collects personal data through the following channels:

• Direct Submission: Data you provide when creating an account, completing KYC verification, making a deposit or withdrawal request, contacting support, or submitting a complaint.
• Automated Collection: Data collected automatically as you browse and interact with jae9.io, including through cookies, session tracking, server logs and analytics tools.
• Third-Party Sources: Data received from KYC verification partners, fraud detection services, payment processors, and (where applicable) publicly available databases used to verify identity and screen for sanctions compliance.
• Device and Network Data: Technical data collected by our servers as a natural result of your device establishing a connection with jae9.io, including IP address, device fingerprint and connection metadata.

How We Use Your Data

jae9 processes personal data only for defined, legitimate purposes. The following table summarises the purposes for which each category of data is used:

• Account Management: To create, maintain and manage your jae9 player account, including authentication, password resets and account preference updates.
• Identity Verification (KYC): To verify your identity, age and payment method ownership in compliance with anti-money-laundering obligations and to enforce the 21+ age restriction.
• Payment Processing: To process deposits and withdrawals in BDT via bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank, Visa and Mastercard.
• Gameplay & Platform Delivery: To deliver casino games, live casino sessions, sports betting markets and other platform features to your device.
• Fraud Prevention & Security: To detect, investigate and prevent fraudulent activity, multi-accounting, bonus abuse, money laundering, match-fixing and other prohibited activities.
• Responsible Gaming: To monitor gambling patterns for indicators of problem gambling and to deliver responsible gaming interventions such as deposit limit enforcements, reality checks and self-exclusion management.
• Customer Support: To respond to your enquiries, complaints and support requests via live chat, email and WhatsApp.
• Legal Compliance: To fulfil obligations imposed by applicable anti-money-laundering legislation, sanctions screening requirements, and any lawful requests from competent authorities.
• Platform Improvement: To analyse aggregated, anonymised usage data to improve the platform's performance, user experience and game selection.
• Marketing Communications (where consented): To send you promotional offers, bonus notifications and platform news by email or SMS, where you have explicitly opted in. You may opt out at any time using the unsubscribe mechanism included in all marketing communications.

Legal Basis for Processing

jae9 processes personal data under the following legal bases:

• Contractual Necessity: Processing required to perform the contract between jae9 and the player — including account creation, payment processing and gameplay delivery — is carried out on the basis of contractual necessity.
• Legal Obligation: Processing required to comply with applicable laws — including KYC verification, AML screening, sanctions compliance and responding to lawful authority requests — is carried out on the basis of legal obligation.
• Legitimate Interests: Processing carried out to detect fraud, prevent abuse, protect platform security, and improve platform features is based on jae9's legitimate business interests, provided those interests are not overridden by the player's fundamental rights and freedoms.
• Consent: Processing for marketing communications and non-essential cookies is carried out on the basis of your freely given, specific and informed consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Sharing Your Data

jae9 shares personal data with third parties only where strictly necessary, and only with parties who are contractually bound to process that data securely, in accordance with this Policy and for no purpose beyond the stated purpose of the disclosure. Categories of recipients include:

• Payment Processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank, Visa and Mastercard — solely to process your deposit and withdrawal transactions.
• KYC & Identity Verification Partners: Third-party identity verification services used to confirm age, identity and document authenticity as part of the KYC process.
• Fraud Detection Services: Third-party anti-fraud and risk management platforms that analyse transaction and gameplay data to identify suspicious patterns.
• Game Providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi and other certified studios receive session data necessary to deliver their games within the jae9 platform.
• IT Infrastructure Providers: Cloud hosting, content delivery network and cybersecurity providers that power the technical infrastructure of jae9.io.
• Legal & Regulatory Authorities: Law enforcement agencies, financial intelligence units and other competent authorities where jae9 is required by law or valid legal process to disclose personal data.
• Professional Advisers: Lawyers, auditors and consultants bound by professional confidentiality obligations, where necessary to obtain professional advice or conduct legal proceedings.

Data Retention

jae9 retains personal data only for as long as is necessary to fulfil the purposes described in this Policy, or as required by applicable legal obligations. The following retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised. Where data has been anonymised, it may be retained indefinitely for statistical and platform improvement purposes, as it can no longer be used to identify any individual.

Data Security

jae9 implements a comprehensive suite of technical and organisational security measures to protect personal data against unauthorised access, accidental loss, destruction, alteration or disclosure. Key security measures include:

• 256-Bit SSL/TLS Encryption: All data transmitted between your device and jae9 servers is encrypted using industry-standard 256-bit SSL/TLS protocols. The connection is enforced via HTTPS on every page of jae9.io.
• Password Hashing: Account passwords are never stored in plain text. jae9 uses bcrypt hashing with a high work factor to store password credentials, making brute-force attacks computationally infeasible.
• PCI-DSS Compliant Payments: Card payment transactions are processed exclusively through PCI-DSS Level 1 compliant payment gateways. jae9 does not store full card numbers on its own servers.
• Two-Factor Authentication (2FA): Players are encouraged to enable two-factor authentication on their jae9 accounts for an additional layer of login security.
• Access Controls: Access to personal data within jae9's internal systems is governed by role-based access controls. Only personnel with a legitimate operational need are granted access to specific data sets.
• Intrusion Detection & Monitoring: jae9 operates 24/7 automated intrusion detection systems and security information and event management (SIEM) tools to monitor for anomalous activity.
• Regular Security Audits: jae9 engages independent cybersecurity firms to conduct periodic penetration testing and vulnerability assessments of the platform infrastructure.

Cookies & Tracking Technologies

jae9 uses cookies and similar tracking technologies (including web beacons, pixel tags and session tokens) to operate and improve the platform. Cookies are small text files stored on your device that allow jae9 to recognise your browser, maintain your session, and personalise certain aspects of your experience.

The following categories of cookies are used by jae9:

• Strictly Necessary Cookies: Required for the platform to function. These include session cookies that maintain your login state, security tokens, and cookies that remember your account settings. These cookies cannot be disabled without disrupting platform functionality.
• Functional Cookies: Used to remember your preferences such as language settings, display preferences and responsible gaming tool configurations. Disabling these cookies may reduce personalisation but will not prevent you from using the platform.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players navigate jae9.io, which pages are visited most frequently, and where technical errors occur. This data is used solely to improve the platform. These cookies are deployed with your consent.
• Marketing Cookies: Used, where you have consented, to deliver relevant promotional content. jae9 does not deploy third-party advertising cookies or share cookie data with advertising networks.

You may manage your cookie preferences through your browser settings. Most modern browsers allow you to block or delete cookies. Please be aware that blocking strictly necessary cookies will impair your ability to use core platform features including account login and financial transactions. For full details on managing browser cookies, consult your browser's help documentation.

Your Data Rights

jae9 respects your rights over your personal data. Subject to applicable law and certain limitations arising from legal retention obligations, you hold the following rights:

• Right of Access: You have the right to request a copy of the personal data jae9 holds about you and to receive information about how it is processed.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data. You may update certain account details directly through the jae9 account settings panel.
• 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, where you have withdrawn consent, or where processing is unlawful. This right is subject to overriding legal retention obligations (e.g., AML transaction records).
• Right to Restriction: You have the right to request that jae9 restrict processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to processing based on legitimate interests.
• Right to Data Portability: You have the right to receive a copy of the personal data you have provided to jae9 in a structured, commonly used and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Object: You have the right to object to processing of your personal data based on legitimate interests or for direct marketing purposes. jae9 will cease processing for direct marketing purposes immediately upon receipt of an objection.
• Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

Minors & Age Verification

jae9 is strictly an adult platform. Real-money gambling on jae9 is permitted only for players who are 21 years of age or older. jae9 does not knowingly collect personal data from individuals under the age of 21.

Age verification is conducted as part of the account registration and KYC process. Where jae9 discovers, at any time, that a registered account belongs to an individual under 21 years of age, the account will be immediately closed, all gameplay activity will be voided, and any deposits will be returned to the originating payment method to the extent practicable. Any personal data collected in connection with the minor's account will be deleted promptly, except to the extent that retention is required for AML compliance or legal proceedings.

If you are a parent or guardian and believe that a minor in your care has registered an account on jae9 without your knowledge, please contact [email protected] immediately. jae9 will investigate and take corrective action as a matter of priority.

International Data Transfers

As an offshore platform, jae9 operates server infrastructure and engages sub-processors in multiple jurisdictions. As a result, personal data collected from players in Bangladesh may be transferred to and processed in countries outside Bangladesh. Such transfers may include jurisdictions that do not have data protection laws equivalent to those applicable in Bangladesh.

Where personal data is transferred internationally, jae9 ensures that appropriate safeguards are in place to protect your data, including:

• Contractual Safeguards: Data processing agreements containing standard contractual clauses that impose data protection obligations on the recipient consistent with this Policy.
• Adequacy Assessments: Where data is transferred to a jurisdiction assessed as providing an adequate level of data protection, jae9 relies on that adequacy determination as the basis for the transfer.
• Technical Measures: End-to-end encryption of data in transit and at rest, ensuring that even in the event of an interception or unauthorised access, the data cannot be read or exploited.
• Binding Corporate Rules: Where transfers occur within a group of entities, binding internal data protection policies govern the processing of personal data across all group entities.

By registering an account and using jae9, you acknowledge and consent to the transfer of your personal data to jurisdictions outside Bangladesh as described in this section. If you have questions about the safeguards applied to specific international transfers, please contact jae9 at [email protected].

Third-Party Services

jae9.io may contain links to third-party websites or services, including game provider portals, payment gateway interfaces and partner pages. This Privacy Policy applies solely to data collected and processed by jae9 through the jae9.io platform. jae9 is not responsible for the privacy practices of any third-party website or service, and we encourage you to review the privacy policies of any third-party service you access via jae9.

Game providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe and Ezugi operate their own technology infrastructure to deliver game content within the jae9 environment. While these providers receive the minimum data necessary to deliver their games (such as session tokens and player identifiers), they are bound by data processing agreements with jae9 and are not permitted to use that data for any purpose beyond game delivery and fraud detection.

Payment processors including bKash, Nagad, Rocket and Upay operate their own data processing environments governed by their own terms and privacy policies. When you initiate a payment through one of these services, you interact directly with that provider's platform, and its own privacy policy applies to the data you submit during that transaction.

Changes to This Policy

jae9 reviews this Privacy Policy periodically and reserves the right to update it at any time to reflect changes in our data processing practices, applicable law, platform features, or the structure of our business operations.

When changes are made, the "Last updated" date at the top of this page will be revised to reflect the date of the most recent amendment. Where a change is material — meaning it significantly affects the rights of players or the way in which jae9 processes personal data — jae9 will notify registered players by email at least 14 days before the change takes effect.

Where a change requires fresh consent (for example, if jae9 introduces a new category of data processing for which consent is the legal basis), jae9 will seek that consent explicitly before commencing the new processing activity. Your continued use of jae9 following the effective date of a non-material amendment constitutes your acceptance of the revised Policy.

We encourage you to review this Policy periodically to stay informed about how jae9 protects your personal data. Archived versions of previous Privacy Policies are available on request from [email protected].

Contact Us

If you have any questions, concerns or requests regarding this Privacy Policy or the way in which jae9 processes your personal data, please reach out to our support and data privacy team using the contact details below. All data privacy correspondence should be submitted in English to ensure prompt handling.