kul9 Privacy Policy

1.Introduction

kul9 is committed to protecting the privacy of every player who uses our platform. This Privacy Policy describes how kul9 collects, uses, stores, shares, and safeguards personal information when you access or use our website, mobile applications, and related services (together, the "Platform"). By continuing to use the Platform, you acknowledge that you have read this policy and consent to the data practices described herein. If you do not agree, please discontinue use of the Platform immediately.

This policy is written in clear, plain English so that every player — whether accessing kul9 from Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, or anywhere else in Bangladesh — can understand what personal data we hold, how we use it, and what rights they have. For any questions not answered here, contact us at [email protected].

2.Information We Collect

kul9 collects the following categories of data when you register, verify your account, transact, or interact with the Platform. We limit collection strictly to what is necessary for each purpose.

3.How We Use Your Information

kul9 processes your personal data for specific, lawful purposes only. We do not use your data beyond what is described below.

• To create and manage your player account, verify your identity, and process KYC documentation as required by our anti-fraud and responsible gaming obligations.
• To process deposits and withdrawals, reconcile financial transactions, and maintain accurate account balances in line with our payment provider agreements with bKash, Nagad, and Rocket.
• To provide customer support, respond to your inquiries, investigate complaints, and resolve disputes relating to your account or gaming activity.
• To personalise your experience, including tailoring promotional offers, game recommendations, and Platform content to your usage history and stated preferences.
• To comply with applicable laws and lawful requests from authorities, including anti-money laundering, responsible gaming regulations, and data protection obligations.
• To monitor Platform usage for the purposes of improving our services, detecting technical faults, identifying security threats, and preventing fraudulent or collusive activity.

4.Legal Basis for Processing

kul9 processes your personal data only where it has a clear lawful basis. The bases we rely upon are:

• Contract performance — processing is necessary to fulfil our obligations under the Terms and Conditions you accepted at registration, including managing your account, processing payments, and delivering gaming services.
• Legal obligation — processing is required to comply with applicable laws, including KYC, anti-money laundering, and responsible gaming regulations that apply to our platform.
• Legitimate interests — processing is necessary for our legitimate interests in preventing fraud, maintaining platform security, and improving our services, where those interests do not override your fundamental rights.
• Consent — where we rely on your consent, such as for optional marketing communications, you may withdraw that consent at any time by contacting [email protected].

5.Sharing Your Information

kul9 does not sell or rent your personal data. We share information only with the following categories of recipients, only to the extent necessary, and only where we have a lawful basis:

• Payment processors and mobile banking partners — such as bKash, Nagad, and Rocket, solely to process your deposit and withdrawal transactions securely.
• KYC and identity verification providers — third-party services engaged to verify identity documents you submit during account verification, as required by our compliance framework.
• Game technology providers — including Pragmatic Play, Evolution Gaming, and other certified studios whose software powers the games on our Platform. These providers receive only the minimum technical data required to deliver their services.
• Regulatory and law enforcement authorities — where we are legally required to disclose information in response to a valid court order, regulatory request, or investigation into suspected unlawful activity.

All third parties with whom kul9 shares personal data are bound by confidentiality obligations and may use your data only for the specific purpose for which it was shared. We do not authorise any third party to use your data for their own independent marketing.

6.Cookies and Tracking Technologies

kul9 uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device that helps us recognise returning users, remember preferences, and understand how the Platform is used. We use three types:

• Essential cookies — strictly necessary to keep the Platform running, maintain your login session, and protect against security threats. These cannot be disabled without breaking core functionality.
• Analytics cookies — used to understand which pages players visit most, how long they stay, and where technical issues arise. Data is aggregated and anonymised wherever possible.
• Functional cookies — allow the Platform to remember your preferences such as language settings and recently played games, providing a more consistent experience across sessions.

You can manage or disable non-essential cookies through your browser settings at any time. Note that disabling essential cookies may prevent parts of the Platform from functioning correctly. kul9 does not serve third-party advertising cookies.

7.Data Retention

kul9 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Account data and transaction records are retained for a minimum of five years from account closure to satisfy anti-money laundering and regulatory requirements. KYC documents are retained for the period required by applicable identity verification regulations. Technical and anonymised usage data may be retained indefinitely for analytical purposes.

When your data is no longer needed, kul9 will securely delete or anonymise it in accordance with industry-standard disposal practices. Requests to close your account are processed subject to any overriding legal retention obligations.

8.Your Rights

As a kul9 user, you have the following rights regarding your personal data. To exercise any of these rights, contact us at [email protected]. We will respond to all verified requests within a reasonable timeframe.

• Right of access — you may request a copy of all personal data kul9 holds about you at any time.
• Right to rectification — if any data we hold about you is inaccurate or incomplete, you may ask us to correct or update it promptly.
• Right to erasure — you may request deletion of your personal data where it is no longer necessary for the purpose it was collected, subject to our legal retention obligations.
• Right to restrict processing — in certain circumstances, you may ask us to suspend processing of your data while a complaint or concern is under investigation.
• Right to data portability — where technically feasible, you may request a copy of the data you provided to us in a structured, commonly used, machine-readable format.

Some rights may be limited where kul9 has overriding legal obligations, such as retaining financial records for regulatory compliance. We will always explain clearly if any limitation applies to your specific request.

9.Security Measures

kul9 implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or unlawful disclosure. These measures include SSL/TLS encryption for all data in transit between your device and our servers, access-controlled secure storage, regular security assessments, and internal staff training on data protection obligations.

While kul9 takes all reasonable precautions, no method of electronic transmission or storage is completely secure. In the unlikely event of a data breach that poses a material risk to your rights, kul9 will notify affected users promptly and take all steps necessary to contain and remediate the incident.

10.Third-Party Services

The kul9 Platform integrates third-party game providers and payment partners whose services are subject to their own privacy policies. kul9 is not responsible for the data practices of those external services. We recommend reviewing the privacy policy of any third-party service you interact with through our Platform. kul9 does not link to external websites unrelated to the services we provide.

11.Children and Minors

The kul9 Platform is strictly for adults aged 21 and above. We do not knowingly collect personal data from anyone under 21 years of age. If we become aware that a minor has registered or provided personal data, we will immediately suspend the account and delete all associated data. If you believe a minor has accessed the Platform, please contact us at [email protected] so we can act promptly. Account holders are responsible for ensuring minors in their household cannot access the Platform.

12.Changes to This Policy

kul9 may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or the services we offer. When we make material changes, we will update the effective date at the top of this page. We encourage you to review this policy periodically so you remain informed about how we protect your information.

Your continued use of the Platform after any update to this Privacy Policy constitutes acceptance of the revised terms. If you disagree with any changes, you should stop using the Platform and contact our support team to close your account.

13.Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or how kul9 handles your personal data, please contact our privacy team by email at [email protected]