qu9 Privacy Policy

1. Data Controller

qu9 acts as the data controller in respect of the personal data collected through the Platform. This means qu9 determines the purposes and means by which your personal data is processed. All enquiries regarding data processing should be directed to our support team at [email protected].

2. Personal Data We Collect

qu9 collects personal data in the following categories:

• Registration data: full name, date of birth, mobile phone number, email address, and account credentials (username and encrypted password).
• Identity verification data: government-issued identity document number, photograph, and any supporting documentation submitted to satisfy our know-your-customer (KYC) obligations.
• Payment data: bKash or Nagad mobile wallet numbers, Rocket account details, Upay account identifiers, Visa or Mastercard card numbers (last four digits only — full card numbers are handled by our payment processor and are not stored on our servers), and transaction histories.
• Device and technical data: IP address, device type, operating system, browser type and version, referring URLs, and session timestamps.
• Behavioural data: gaming activity records, betting history, session duration, game preferences, bonus redemption history, and deposit and withdrawal records.
• Communications data: the content of any messages you send to qu9 support, including live chat transcripts and email correspondence.
• Responsible gaming data: any deposit limits, self-exclusion periods, cooling-off periods, or session time reminders you have set on your Account.

3. How We Collect Your Data

qu9 collects personal data through the following means:

• Directly from you — when you register an account, make a deposit or withdrawal, submit a support request, or update your profile settings.
• Automatically — through cookies, web beacons, and similar technologies when you access and navigate the Platform. See Section 8 (Cookies) for full details.
• From third-party payment providers — transaction confirmation data returned by payment processors such as bKash, Nagad, Rocket, and Upay when you initiate a deposit or withdrawal.
• From identity verification partners — where we engage third-party KYC service providers to assist with document verification, those providers may return verification status and associated data to us.

4. How We Use Your Personal Data

qu9 processes your personal data only for the following legitimate purposes:

• Account creation and management: to register your account, maintain accurate records, and provide you with access to the Platform.
• Identity verification: to verify that you meet the 21+ age requirement and to comply with applicable anti-money-laundering and know-your-customer regulations.
• Payment processing: to process deposits and withdrawals via your chosen payment method, including bKash, Nagad, Rocket, Upay, Visa, and Mastercard.
• Platform personalisation: to tailor your gaming experience, remember your preferences, and display relevant promotions (such as BPL cricket betting offers or slot tournament notifications).
• Fraud prevention and security: to detect and prevent fraudulent activity, money laundering, multi-accounting, and other prohibited conduct described in our Terms & Conditions.
• Customer support: to respond to your enquiries, investigate complaints, and resolve disputes.
• Responsible gaming: to administer self-exclusion requests, deposit limits, cooling-off periods, and other player-protection tools you have requested.
• Legal compliance: to comply with applicable laws, regulatory requirements, court orders, and law enforcement requests.
• Platform improvement: to analyse aggregate usage patterns, diagnose technical issues, and improve the performance and content of the Platform.

qu9 does not process your personal data for automated decision-making that produces legal effects, nor does it use your data to build marketing profiles for sale to third parties.

5. Legal Basis for Processing

qu9 relies on the following legal bases to process your personal data:

• Contractual necessity: processing is required to fulfil our obligations to you under the Terms & Conditions, including account management and payment processing.
• Legal obligation: processing is required to comply with applicable laws, including anti-money-laundering regulations and age verification requirements.
• Legitimate interests: processing is necessary for our legitimate interests in operating a secure and fraud-free gaming platform, provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: for optional marketing communications and non-essential cookies, processing is based on your explicit consent. You may withdraw consent at any time by contacting [email protected].

6. Data Sharing and Disclosure

qu9 does not sell or rent your personal data. We share your data only in the following limited circumstances:

• Payment processors: we share the minimum data required with bKash, Nagad, Rocket, Upay, Visa, and Mastercard processing partners to execute deposit and withdrawal transactions.
• Identity verification providers: where third-party KYC services are used to verify your identity documents, we share the documents and data necessary for that verification.
• Technology service providers: hosting, analytics, and infrastructure partners who process data on our behalf under strict contractual data processing agreements that prohibit independent use of your data.
• Legal and regulatory authorities: where required by applicable law, court order, or legitimate request from a competent authority, we may disclose your data to law enforcement or regulatory bodies.
• Business transfers: in the event of a merger, acquisition, or sale of substantially all of qu9's assets, your data may be transferred as part of that transaction, subject to equivalent privacy protections.

In all cases, qu9 takes reasonable steps to ensure that third parties receiving your data are bound by appropriate confidentiality and data protection obligations.

7. Data Retention

7.1 qu9 retains your personal data only for as long as is necessary to fulfil the purposes described in this Policy, or as required by applicable law. Specific retention periods are as follows:

• Account data: retained for the duration of your Account plus a minimum of five (5) years following account closure, to satisfy anti-money-laundering record-keeping requirements.
• Transaction records: retained for a minimum of five (5) years from the date of each transaction.
• Identity verification documents: retained for a minimum of five (5) years following account closure.
• Support and communications records: retained for a minimum of two (2) years from the date of the most recent communication.
• Technical and device data: retained for a maximum of thirteen (13) months from collection.

7.2 Once the applicable retention period has expired and no legal obligation requires further retention, qu9 will securely delete or anonymise the relevant data.

8. Cookies and Tracking Technologies

8.1 qu9 uses cookies and similar tracking technologies to operate and improve the Platform. The categories of cookies we use are:

• Strictly necessary cookies: required for the Platform to function, including session management and security tokens. These cannot be disabled.
• Performance cookies: collect anonymous data about how players interact with the Platform (e.g., which pages are visited most frequently) to help us improve performance. No personally identifiable information is collected by these cookies.
• Functionality cookies: remember your preferences such as language settings, preferred payment method, and game history for a more personalised experience.
• Analytics cookies: used to measure aggregate traffic and user behaviour patterns on the Platform. Data collected is anonymised and used solely for internal analytical purposes.

8.2 You may manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. Strictly necessary cookies cannot be declined as they are essential to the Platform's operation.

9. Your Data Rights

As a user of the qu9 Platform, you have the following rights in relation to your personal data:

10. Data Security

10.1 qu9 implements a range of technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the Platform;
• Encrypted storage of passwords using industry-standard hashing algorithms;
• Restricted access controls ensuring that only authorised qu9 personnel can access personal data on a need-to-know basis;
• Regular security assessments and vulnerability testing of Platform infrastructure;
• Secure data centres with physical access controls.

10.2 Despite these measures, no system is completely immune to security threats. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, qu9 will notify affected players without undue delay and take all reasonable steps to mitigate the impact of the breach.

10.3 You are responsible for keeping your account password confidential. qu9 will never ask you for your password via email, chat, or phone.

11. Age Restrictions and Minor Players

The qu9 Platform is strictly intended for adults aged 21 years and above. qu9 does not knowingly collect personal data from individuals under the age of 21. If we discover that personal data has been collected from a person under 21, we will immediately close that account, delete the associated personal data, and return any balance to the payment method on file. If you believe a person under 21 has registered on the Platform, please notify us immediately at [email protected].

12. Third-Party Links and Services

The qu9 Platform does not contain links to third-party websites for commercial or advertising purposes. Where third-party services are integrated into the Platform (such as payment processors), those services operate under their own privacy policies. qu9 is not responsible for the privacy practices of third-party service providers beyond the contractual data processing obligations described in Section 6 of this Policy.

13. International Data Transfers

13.1 qu9 primarily processes and stores data within secure data centre infrastructure. Where data is transferred to or processed by service providers located outside Bangladesh, qu9 takes appropriate safeguards to ensure an equivalent level of data protection, including the use of contractual data processing agreements that require recipients to protect your data to standards consistent with this Policy.

13.2 By using the Platform, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside your country of residence. qu9 will always ensure that such transfers are conducted lawfully and with appropriate protections in place.

14. Updates to This Privacy Policy

14.1 qu9 reserves the right to update or amend this Privacy Policy at any time. When material changes are made, we will post the revised Policy on the Platform with an updated effective date. Continued use of the Platform after the revised Policy takes effect constitutes your acceptance of the changes.

14.2 We recommend reviewing this Policy periodically to stay informed about how qu9 protects your personal data. The current version is always available at qu9.bio/privacy-policy.

15. Contact Us

For all privacy-related enquiries, data access requests, or complaints about how qu9 handles your personal data, please contact our support team:

Email: [email protected]

Our team is available 24 hours a day, 7 days a week. We aim to respond to all privacy-related requests within 30 days of receipt.