Privacy Policy

1. Introduction

1.1 bull99a takes its obligations with respect to personal data seriously. This Privacy Policy has been prepared to be transparent about the categories of data we collect, the purposes for which we use it, the parties with whom we share it, and the rights you hold in relation to your personal data.

1.2 bull99a operates under applicable international gaming authority frameworks that impose specific requirements on the collection and handling of player data — including know-your-customer (KYC) verification, anti-money laundering (AML) record-keeping, and responsible gaming monitoring. Some data processing activities are therefore mandatory obligations, not discretionary choices.

1.3 This Policy applies to all personal data processed in connection with the bull99a platform, including data collected through the website at https://bull99a.org, any mobile-optimised versions of the platform, and communications between players and the bull99a support team.

2. Personal Data We Collect

2.1 bull99a collects personal data in the following categories:

2.2 bull99a does not collect sensitive personal data categories such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data except where identity document photography is required for KYC verification and is stored solely for that purpose.

3. How We Use Your Personal Data

3.1 bull99a uses your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your bull99a account; processing your login and authentication requests;
• Transaction processing: Handling deposits and withdrawals via Touch 'n Go eWallet, DuitNow, GrabPay, Boost, FPX, and other accepted payment methods; generating transaction records;
• Regulatory compliance: KYC identity verification; AML transaction monitoring; regulatory reporting obligations; age verification (mandatory 21+ enforcement);
• Platform delivery: Personalising your game lobby experience; remembering your preferences; ensuring platform security and integrity;
• Customer support: Responding to your enquiries; resolving disputes; maintaining support records;
• Responsible gaming: Monitoring wagering patterns for indicators of problem gambling; enforcing deposit limits and self-exclusion instructions; generating responsible gaming alerts;
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates — only where you have opted in to receive such communications; and
• Platform improvement: Analysing aggregated usage data to improve game selection, platform performance, and user experience.

4. Legal Basis for Processing

4.1 bull99a processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and bull99a — including account creation, game access, and transaction processing;
• Legal obligation: Processing required to comply with applicable laws and regulatory requirements — including KYC, AML, and age verification obligations;
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring where our legitimate interests are not overridden by your rights; and
• Consent: Processing for marketing communications where you have provided explicit opt-in consent, which you may withdraw at any time.

5. Sharing Personal Data with Third Parties

5.1 bull99a does not sell, rent, or otherwise transfer your personal data to third parties for their own marketing purposes. Personal data is shared with third parties only in the following circumstances:

• Payment processors: Financial data necessary to process your deposits and withdrawals is shared with relevant payment service providers (including Touch 'n Go, GrabPay, Boost, and participating FPX banks) solely for transaction processing purposes;
• Game providers: Technical identifiers and wager data are shared with game software providers (such as Evolution Gaming, Pragmatic Play, and PG Soft) to facilitate gameplay. These providers do not receive your full identity data;
• KYC and compliance service providers: Identity documents and verification data are processed by third-party KYC service providers under strict confidentiality and data processing agreements;
• Regulatory authorities: Personal data is disclosed to gaming regulators, financial intelligence units, and law enforcement agencies where required by applicable law or regulatory direction; and
• Technology infrastructure providers: Cloud hosting and data storage providers who process data on bull99a's behalf under contractual data processing agreements that prohibit independent use of your data.

5.2 All third parties with whom bull99a shares personal data are required to implement appropriate technical and organisational security measures and to use the data only for the purposes for which it was shared.

6. Data Retention

6.1 bull99a retains personal data for as long as is necessary to fulfil the purposes set out in this Policy and to comply with applicable legal and regulatory retention requirements.

6.2 As a general principle:

• Account and identity data is retained for the duration of your account and for a minimum of 5 years following account closure, in accordance with standard AML record-keeping requirements;
• Financial transaction records are retained for a minimum of 5 years from the date of the transaction;
• Support communications are retained for 3 years from the date of the interaction; and
• Technical and usage data is retained in aggregated, anonymised form for platform analytics; raw identifiable logs are retained for up to 12 months.

6.3 Where retention beyond these periods is required by a specific legal obligation or pending dispute resolution, data will be retained for the duration of that obligation or proceeding.

7. Cookies and Tracking Technologies

7.1 bull99a uses cookies and similar tracking technologies on the platform for the following purposes:

• Essential cookies: Necessary for the platform to function — including session management, authentication, and security token handling. These cannot be disabled without impairing your ability to use the platform;
• Functional cookies: Used to remember your preferences, including language settings and responsible gaming limit configurations;
• Analytics cookies: Used to understand how players navigate the platform, which games are most popular, and where technical errors occur. Data collected via analytics cookies is aggregated and does not identify you individually.

7.2 bull99a does not use third-party advertising or retargeting cookies. You will not see bull99a advertisements following you across other websites as a result of using the platform.

7.3 You may configure your browser to reject cookies. Note that disabling essential cookies will prevent you from logging in to your bull99a account.

8. Security Measures

8.1 bull99a implements the following technical and organisational security measures to protect your personal data:

• 256-bit TLS encryption for all data transmitted between your device and the bull99a platform;
• Encryption at rest for all stored personal and financial data;
• Hashed and salted password storage — your password is never stored in readable form;
• Role-based access controls — bull99a staff access to player data is restricted on a need-to-know basis;
• Regular security assessments and penetration testing of platform infrastructure;
• Automated anomaly detection for unusual login patterns, which may trigger account protection measures; and
• Incident response procedures for data security events, including notification procedures where legally required.

8.2 Despite these measures, no online platform can guarantee absolute security. You are encouraged to use a strong, unique password for your bull99a account and to enable two-factor authentication.

9. Your Rights in Relation to Your Personal Data

9.1 Subject to applicable law, you have the following rights in relation to the personal data bull99a holds about you:

• Right of access: You may request a copy of the personal data bull99a holds about you;
• Right to rectification: You may request correction of inaccurate or incomplete personal data;
• Right to erasure: You may request deletion of personal data that is no longer necessary for the purposes for which it was collected — subject to bull99a's legal retention obligations;
• Right to restrict processing: In certain circumstances, you may request that bull99a limit the way in which your data is processed while a query is being resolved;
• Right to withdraw consent: Where processing is based on consent (e.g., marketing communications), you may withdraw consent at any time without affecting the lawfulness of prior processing; and
• Right to lodge a complaint: You may lodge a complaint with the relevant data protection authority in your jurisdiction.

9.2 To exercise any of the above rights, contact bull99a Support via live chat or at the email address provided in Section 12. bull99a will respond to all valid requests within 30 days.

10. Children and Minors

10.1 bull99a's platform is strictly for individuals aged 21 years and above. bull99a does not knowingly collect personal data from individuals under the age of 21. If bull99a becomes aware that personal data has been collected from a person under 21, that account will be suspended and the data deleted or returned as appropriate.

10.2 If you believe that a person under 21 has registered on the bull99a platform, please notify bull99a Support immediately.

11. Changes to This Privacy Policy

11.1 bull99a reserves the right to update this Privacy Policy at any time. Where material changes are made, registered Players will be notified via a platform notice and, where practicable, by email to the address associated with their account.

11.2 The "Last updated" date at the top of this Policy reflects the most recent revision. Continued use of the bull99a platform following notification of a change constitutes acceptance of the revised Policy.

12. Contact and Complaints

12.1 For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact bull99a through the following channels:

• Live chat: Available 24 hours a day, 7 days a week via the platform;
• Email: [email protected] (plain text — not a clickable link).

12.2 bull99a will acknowledge all data-related requests within 5 business days and provide a substantive response within 30 days. Where a request is complex or where you have submitted multiple concurrent requests, this period may be extended by a further 30 days, with notice provided to you.

12.3 If you are not satisfied with bull99a's response to a privacy complaint, you may escalate the matter to the relevant data protection authority or regulatory body applicable in your jurisdiction.