93ko Privacy Policy

1 Introduction

93ko ("we", "us", "our") operates the online casino and sports betting platform accessible at https://93ko.io (the "Platform"). We are committed to protecting the personal data of every individual who visits, registers on, or interacts with the Platform, including players based in Bangladesh and any other jurisdiction in which our services are accessible.

This Privacy Policy ("Policy") sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed, stored, and used. "Personal data" means any information that identifies or could reasonably identify a living individual, including name, date of birth, email address, mobile number, payment details, device identifiers, and usage behaviour.

By accessing the Platform or registering an Account, you acknowledge that you have read, understood, and agree to the data practices described in this Policy. If you do not agree with any part of this Policy, please cease using the Platform and contact [email protected] to arrange Account closure.

This Policy should be read alongside our Terms & Conditions and our Responsible Gaming policy, both of which contain provisions relevant to the way your data may be used in the context of your gambling activity.

2 Data We Collect

We collect and process the following categories of personal data in connection with your use of the 93ko Platform:

We do not collect or store sensitive special-category personal data such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, biometric data (beyond a liveness selfie for KYC verification), or health information, except where strictly required by applicable anti-money laundering regulations.

3 How We Collect Your Data

93ko collects personal data through the following channels and mechanisms:

• Direct Interactions: Data you actively provide when creating an Account, completing the KYC verification process, making a deposit or withdrawal, activating a responsible gaming tool, or contacting our support team.
• Automated Technologies: Technical and usage data collected automatically when you access the Platform, including data gathered via cookies, web beacons, server logs, and session-tracking scripts. See Section 7 for full details on cookies.
• Third-Party Payment Processors: Transaction confirmation data, payment method identifiers, and fraud-screening signals received from our payment partners (bKash, Nagad, Rocket, Upay, Visa acceptance networks, and Mastercard acceptance networks) when you conduct cashier operations.
• Identity Verification Providers: Results of identity document authentication and liveness checks performed by our KYC technology partner on your behalf when you submit verification documents.
• Fraud Prevention & Analytics Services: Aggregated risk signals and device fingerprint data from fraud detection partners used to identify suspicious access patterns, bot activity, or multi-account abuse. These partners process data under strict data processing agreements and do not use 93ko player data for their own commercial purposes.
• Game Providers: Game session outcomes, RNG seeds, and wagering records transmitted from certified game providers (Pragmatic Play, Evolution Gaming, JILI Games, NetEnt, Microgaming, Spribe, Ezugi, and others) to 93ko's back-end systems for account settlement and dispute resolution purposes.

4 Purpose of Processing

We process your personal data only for the specific, legitimate purposes listed below. We do not process personal data for any purpose that is incompatible with the purpose for which it was originally collected.

• Account Creation & Management: To register your Account, authenticate your identity at login, and maintain your Account profile and preferences throughout the period of our relationship.
• Age & Identity Verification (KYC): To verify that you meet the mandatory 21+ age requirement and to confirm your identity in accordance with anti-money laundering (AML) obligations before processing your first withdrawal.
• Payment Processing: To facilitate deposits and withdrawals in Bangladeshi Taka (BDT) via your chosen payment method, to reconcile transaction records, and to investigate and resolve payment disputes.
• Game & Sportsbook Services: To deliver, operate, and settle games and betting markets, to maintain complete wagering history for dispute resolution, and to calculate and credit winnings correctly to your Account balance.
• Bonus & Promotions Administration: To determine your eligibility for promotional offers, to track wagering requirement progress, and to credit or reclaim bonus funds in accordance with applicable promotion terms.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, multi-account abuse, money laundering, bot use, and other prohibited conduct as defined in our Terms & Conditions.
• Responsible Gaming: To record and enforce deposit limits, session time reminders, cooling-off periods, and self-exclusion requests activated by you or applied by 93ko under its responsible gaming obligations.
• Customer Support: To respond to your support enquiries, to investigate and formally resolve complaints, and to maintain a record of our communications for quality assurance and audit purposes.
• Legal & Regulatory Compliance: To meet our obligations under applicable law, including responding to lawful requests from financial intelligence units and law enforcement authorities, and to retain records for the periods required by law.
• Platform Improvement & Analytics: To analyse aggregated usage patterns, game performance, and player journey data in order to improve the functionality, content, and user experience of the Platform.
• Marketing Communications: Where you have provided explicit consent, to send you promotional emails or on-platform notifications about new games, bonuses, or seasonal promotions relevant to your account profile. You may withdraw marketing consent at any time by contacting [email protected].

5 Legal Basis for Processing

For each processing activity described in Section 4, 93ko relies on one or more of the following legal grounds:

• Contractual Necessity: Processing required to perform our contract with you — namely, to operate your Account, deliver games and betting markets, and process deposits and withdrawals. Without this processing the service cannot be provided.
• Legal Obligation: Processing required to comply with applicable law, including KYC / AML verification, financial record retention, and responding to lawful regulatory or law-enforcement requests.
• Legitimate Interests: Processing carried out for fraud prevention, multi-account detection, Platform security, responsible gaming enforcement, and aggregate analytics — activities in which 93ko has a genuine legitimate interest that is not overridden by your fundamental rights and freedoms.
• Consent: Processing activities that go beyond what is strictly necessary for service delivery and legal compliance — specifically, direct marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

6 Data Sharing & Disclosure

93ko does not sell, rent, or trade your personal data. We share personal data only where strictly necessary with the following categories of recipients, each of whom is subject to appropriate data protection safeguards:

• Payment Processors: bKash, Nagad, Rocket, Upay, and card network acquirers receive the minimum data required to authorise and settle your transactions. These parties are subject to their own applicable financial data regulations.
• KYC / Identity Verification Providers: Our identity verification technology partner receives your submitted identity documents and selfie images solely for the purpose of performing document authentication and liveness checks. Documents are not retained by the provider beyond the verification process.
• Game Providers: Pragmatic Play, Evolution Gaming, JILI Games, NetEnt, Microgaming, Spribe, Ezugi, and other certified providers receive a pseudonymous player identifier and session token to deliver game content. They do not receive your full name, contact details, or financial data.
• Fraud Detection & Cybersecurity Partners: Receive device fingerprint data, IP address ranges, and behavioural signals for real-time fraud screening. All processing is subject to contractual data processing agreements limiting use to fraud prevention only.
• Analytics Providers: Receive anonymised or pseudonymised usage data for aggregate Platform analytics. Individual player identities are not shared with analytics providers.
• Legal & Regulatory Authorities: Where 93ko is subject to a lawful request from a financial intelligence unit, law enforcement agency, or court of competent jurisdiction, we are legally required to disclose the specified personal data. We will notify you of such a request where permitted by law.
• Professional Advisers: Lawyers, auditors, and accountants engaged by 93ko may access personal data on a strictly need-to-know basis in connection with professional engagements. All such advisers are bound by professional confidentiality obligations.

7 Cookies & Tracking Technologies

The 93ko Platform uses cookies and similar technologies to enable core functionality, improve your experience, and gather aggregate analytics data. A "cookie" is a small text file placed on your browser or device when you visit a website.

We use the following categories of cookies on the Platform:

You may control or delete cookies through your browser settings at any time. Disabling strictly necessary or security cookies will impair or prevent access to the Platform. Disabling analytics or functional cookies will not prevent you from playing games or managing your account, but may reduce the quality of your experience.

93ko does not use third-party advertising cookies or behavioural retargeting pixels. We do not participate in cross-site advertising networks.

8 Data Security

93ko applies a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include but are not limited to the following:

• Encryption in Transit: All data transmitted between your browser or device and the 93ko Platform is encrypted using 256-bit TLS (Transport Layer Security). The Platform enforces HTTPS exclusively — unencrypted HTTP connections are not accepted.
• Encryption at Rest: Sensitive personal data and identity document files stored on 93ko's servers are encrypted at rest using AES-256 encryption. Database credentials and API keys are managed through a secrets management system with strict access controls.
• Access Controls: Access to systems holding personal data is restricted to authorised 93ko personnel on a strict need-to-know basis. All internal access is authenticated via multi-factor authentication (MFA) and logged for audit purposes.
• Network Security: The Platform infrastructure is protected by Web Application Firewall (WAF) technology, DDoS mitigation services, intrusion detection systems (IDS), and regular network penetration testing.
• Payment Security: All payment transaction data is handled exclusively by PCI-DSS compliant payment processors. 93ko does not operate its own card data environment and does not store raw card numbers, CVV codes, or mobile wallet PINs.
• Incident Response: In the event of a personal data breach that presents a risk to player rights and freedoms, 93ko will notify affected players without undue delay and will take all necessary remediation steps. A breach register is maintained internally for audit purposes.

9 Data Retention

93ko retains your personal data only for as long as is necessary for the purposes for which it was collected, including satisfying any applicable legal, regulatory, accounting, or reporting obligations. The following retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Anonymised or aggregated data (from which individual identity cannot be reconstructed) may be retained indefinitely for statistical and analytical purposes.

10 Your Privacy Rights

Subject to applicable law and certain limitations where legal obligations require us to retain or restrict access to specific data, you have the following rights in relation to your personal data held by 93ko:

• Right of Access: You may request a copy of all personal data we hold about you, including your Account profile, transaction history, and support communications. We will provide this in a structured, machine-readable format within 30 days of a verified request.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. Minor corrections (e.g., email address, phone number) can be made through your Account settings. Corrections to identity data require submission of updated documentation.
• Right to Erasure ("Right to be Forgotten"): You may request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where consent has been withdrawn, or where processing has no other lawful basis. This right is subject to override where we are required to retain data for legal compliance purposes — particularly AML and financial record obligations.
• Right to Restrict Processing: You may request that we limit the processing of your data (e.g., while a data accuracy dispute is under investigation) without requiring full erasure.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller, where the processing is based on consent or contractual necessity.
• Right to Object: You may object to processing based on legitimate interests at any time. Where the processing concerns direct marketing, objection is absolute and we will cease marketing processing immediately. For other legitimate interest processing, we will evaluate whether our interests are overridden by your rights.
• Right to Withdraw Consent: Where processing is based on your consent (primarily direct marketing), you may withdraw that consent at any time by contacting [email protected]. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

To exercise any of the rights listed above, please submit a written request to [email protected] with the subject line "Data Rights Request". We will acknowledge your request within 5 business days and complete it within 30 calendar days. Where a request is complex or numerous, we may extend this period by a further 30 days, in which case we will notify you in advance.

11 Children's Privacy

The 93ko Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect, solicit, or process personal data from any individual under the age of 21. The Platform employs mandatory age verification as part of the registration process, and KYC verification is required before any withdrawal is processed.

If 93ko becomes aware that personal data has been collected from an individual who has misrepresented their age and is under 21 years old, we will immediately:

• Suspend and permanently close the Account in question.
• Void all game play and reverse any winnings generated on the Account.
• Securely delete all personal data collected in connection with the Account, except to the extent that retention is required for regulatory reporting or fraud prevention purposes.
• Refund verified real-money deposits (net of any bonuses or voided winnings) to the originating payment method where technically possible.

If you are a parent or guardian and believe that a minor in your care has registered an Account on the 93ko Platform, please contact us immediately at [email protected] so that we can take appropriate action without delay.

12 Third-Party Links

The 93ko Platform may contain references to third-party services, game providers, or payment partners. Where a third-party provider's interface is embedded within the Platform (for example, a game window or payment gateway), that provider operates under their own privacy policy and data processing practices. 93ko is not responsible for the privacy practices of third-party providers.

We recommend that you review the privacy policies of any third-party services you interact with in connection with your use of the 93ko Platform. The presence of a third-party integration on the Platform does not constitute an endorsement of that third party's privacy practices.

The 93ko Platform does not display third-party advertising banners, affiliate tracking pixels, or social media widgets that would transmit your data to unrelated third-party advertising networks without your knowledge.

13 Policy Updates

93ko reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, regulatory guidance, or the features and services offered on the Platform. The "Last Updated" date at the top of this document will be revised whenever a material change is made.

Where an update materially affects your rights or the way we process your personal data, we will notify you in advance via the email address registered to your Account and/or via an on-screen notice upon your next login, with at least 7 days' notice before the updated Policy takes effect.

For minor amendments — such as corrections of typographical errors, clarifications of existing language, or updates to contact details — changes may take effect immediately upon publication without prior notice.

Continued use of the Platform after any revision to this Policy constitutes your acceptance of the updated terms. If you do not accept a revised Policy, please discontinue use of the Platform and contact [email protected] to close your Account before the effective date of the change.

The current and authoritative version of this Policy will always be available at https://93ko.io/privacy-policy. Previous versions are archived internally and available on request.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way 93ko processes your personal data, please contact our support team through the following channel:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line for Data Rights Requests: "Data Rights Request"
• Response Time: Within 5 business days for acknowledgement; within 30 calendar days for full resolution.
• Support Hours: 24/7 — Bangladesh Standard Time (BST, UTC+6)
• Market: Bangladesh — Dhaka, Chittagong, Sylhet & nationwide

We take all privacy enquiries seriously. Whether you are seeking to exercise a data right, raise a concern about how your data has been used, or simply require clarification on any part of this Policy, our team is committed to providing a thorough and timely written response.