srd9 Privacy Policy — How We Collect, Use & Protect Your Data

1 About This Policy

This Privacy Policy ("Policy") describes how srd9 International Ltd. ("srd9", "we", "us", "our") collects, processes, stores, shares, and protects personal data relating to registered players, prospective players, and visitors to the srd9 platform accessible at https://srd9.io (the "Platform").

This Policy applies to all personal data processed in connection with your use of the Platform, including data collected during account registration, identity verification, deposits and withdrawals, gameplay, customer support interactions, and general browsing of the srd9 website. It should be read alongside our Terms and Conditions and Responsible Gaming Policy, all of which together form the complete agreement governing your use of srd9.

By registering an account with srd9 or by continuing to use the Platform, you confirm that you have read and understood this Privacy Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, you must cease use of the Platform and request account closure at [email protected].

2 Data Controller

The data controller responsible for your personal data is srd9 International Ltd. As data controller, srd9 determines the purposes and means by which your personal data is processed. For all data protection enquiries, requests, or complaints, please contact our Data Protection contact at:

• Email: [email protected] (plain text — not a clickable link)
• Platform: https://srd9.io
• Response time: All data-related requests acknowledged within 48 hours; resolved within 30 calendar days

Where srd9 engages third-party service providers who process personal data on our behalf (for example, payment processors, identity verification providers, or cloud infrastructure partners), those providers act as data processors under binding data processing agreements with srd9 and are not permitted to use your data for their own independent purposes.

3 Personal Data We Collect

The categories of personal data that srd9 may collect about you are set out in the table below. The specific data points collected in any given interaction will depend on the nature of your activity on the Platform.

4 How We Collect Your Data

srd9 collects personal data through the following channels and methods:

• Direct provision: Data you provide voluntarily when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or responding to surveys.
• Automated collection: Technical and usage data collected automatically as you interact with the Platform, including via cookies, web beacons, server logs, and similar tracking technologies (see Section 10).
• Third-party sources: Identity and fraud-screening data received from licensed identity verification providers and payment processors as part of our KYC and anti-money laundering (AML) procedures.
• Public sources: In limited circumstances, srd9 may cross-reference publicly available information (such as sanctions lists or public court records) as part of our compliance obligations.

You are under no obligation to provide personal data to srd9; however, failure to provide certain mandatory information (such as identity documents required for KYC verification) will prevent srd9 from providing some or all Platform services to you.

5 Legal Basis for Processing

srd9 processes your personal data on the following legal bases, depending on the specific purpose of processing:

• Contractual necessity: Processing required to fulfil our obligations under the account agreement with you, including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering (AML) requirements, age verification obligations, and financial record-keeping mandates.
• Legitimate interests: Processing carried out for the legitimate business interests of srd9, including fraud prevention, platform security, analytics, and responsible gaming monitoring — provided those interests are not overridden by your fundamental rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, such as for optional marketing communications. You may withdraw consent at any time by contacting [email protected] or updating your account notification preferences.

6 How We Use Your Personal Data

srd9 uses the personal data it collects for the following specific, documented purposes:

• To create, verify, and manage your srd9 player account, including age verification to enforce our strict 21+ policy.
• To process deposits, withdrawals, and all financial transactions on the Platform, including verification of payment methods registered in your name.
• To conduct identity verification (KYC) and anti-money laundering (AML) screening as required by our operating procedures and applicable compliance obligations.
• To deliver, maintain, and improve the srd9 Platform, including personalising game recommendations and promotional offers based on your activity and stated preferences.
• To monitor gameplay patterns for the purpose of responsible gaming intervention, including the enforcement of deposit limits, session time limits, and self-exclusion periods.
• To detect, investigate, and prevent fraud, cheating, collusion, money laundering, and other prohibited conduct in accordance with our Terms and Conditions.
• To communicate with you regarding your account, including transactional notifications, security alerts, and responses to your support requests.
• To send you promotional communications about srd9 offers, bonuses, and new games — but only where you have opted in to receive such communications and have not subsequently withdrawn consent.
• To maintain accurate financial and compliance records as required by applicable law, including records of transactions, KYC outcomes, and AML screenings.
• To analyse aggregated, anonymised usage trends for the purpose of improving Platform performance and user experience.

srd9 does not use your personal data to make fully automated decisions that produce significant legal effects concerning you without human review. Where automated processes flag an account for review (for example, as part of fraud screening), the outcome is always reviewed by a qualified member of the srd9 compliance team before any consequential action is taken.

7 Data Sharing & Disclosure

srd9 does not sell, rent, or trade your personal data. We may share your data with the following categories of third parties, strictly on the basis set out below:

• Payment processors: bKash, Nagad, Rocket, Upay, Visa, Mastercard, and domestic banking partners require transaction data to process deposits and withdrawals. These providers process data under their own privacy policies and applicable financial regulations.
• Identity verification providers: Licensed KYC/AML service providers who verify your identity documents and screen against sanctions and politically exposed persons (PEP) lists as required by our compliance framework.
• Game software providers: Third-party game studios (including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and others) may receive limited technical session data necessary to deliver their games within the srd9 Platform. These providers do not receive your identity or financial data.
• Cloud infrastructure and security providers: Server hosting, content delivery, DDoS protection, and cybersecurity vendors who process technical data under strict data processing agreements with srd9.
• Regulatory and law enforcement authorities: Where required by law, court order, or regulatory instruction, srd9 may disclose personal data to competent authorities. We will notify you of any such disclosure where legally permitted to do so.
• Professional advisers: Lawyers, auditors, and compliance consultants who are bound by professional confidentiality obligations and who require access to certain data in the course of providing professional services to srd9.

All third parties with whom srd9 shares personal data are contractually required to maintain the confidentiality and security of that data and to use it only for the specified purpose for which it was shared. srd9 does not permit third-party processors to use your data for their own commercial, marketing, or analytical purposes without your explicit consent.

8 International Data Transfers

srd9 operates a platform that serves players primarily in Bangladesh. Some of our third-party service providers, including cloud infrastructure partners and game studios, may process personal data in jurisdictions outside Bangladesh. Where such international transfers occur, srd9 ensures that appropriate safeguards are in place to protect your data, including:

• Binding contractual clauses (standard contractual clauses) with all recipient parties that impose data protection obligations equivalent to those described in this Policy.
• Use of service providers that maintain internationally recognised security certifications (such as ISO 27001).
• Technical measures including end-to-end encryption of data in transit and at rest.

By using the srd9 Platform, you acknowledge that your personal data may be transferred to and processed in countries other than Bangladesh. In all cases, srd9 takes all reasonably practicable steps to ensure that any such transfers are conducted securely and in accordance with this Policy.

9 Data Retention

srd9 retains personal data for as long as it is necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by applicable law. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be attributed to an identifiable individual. Where anonymised data is retained for statistical or analytical purposes, it no longer constitutes personal data and is not subject to this Policy.

10 Cookies & Tracking Technologies

The srd9 Platform uses cookies and similar tracking technologies (including web beacons and local storage objects) to deliver a secure, functional, and personalised experience. The following categories of cookies are used on the Platform:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management, login state, and security token handling. These cookies cannot be disabled without breaking core Platform functionality.
• Functional cookies: Used to remember your preferences such as language settings, preferred game categories, and display options. Disabling these cookies may reduce the personalised experience but will not prevent you from using the Platform.
• Analytics cookies: Used to collect aggregated, anonymised data about how visitors navigate and interact with the Platform. This data helps srd9 identify areas for improvement and optimise the user experience. No personally identifiable information is associated with analytics cookies.
• Security cookies: Used to detect and prevent fraudulent activity, bot traffic, and unauthorised access attempts. These cookies analyse behavioural signals to distinguish legitimate users from automated threats.

srd9 does not use cookies to build cross-site advertising profiles, serve third-party behavioural advertising, or track your activity on websites outside the srd9 Platform. You may control cookie settings through your browser's privacy settings. Note that disabling strictly necessary or security cookies may impair the functionality or security of your srd9 account session.

11 Security Measures

srd9 implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security framework includes:

• 256-bit TLS/SSL encryption applied to all data transmitted between your device and the srd9 Platform.
• Encryption of sensitive data at rest within our database infrastructure, including financial data and identity verification documents.
• Strict role-based access controls ensuring that only authorised srd9 personnel with a documented need can access personal data.
• Regular penetration testing and vulnerability assessments conducted by independent cybersecurity professionals.
• Multi-factor authentication requirements for all internal srd9 staff accessing systems that store personal data.
• Automated intrusion detection and real-time monitoring of all Platform infrastructure for anomalous activity.
• Documented data breach response procedures, including notification protocols for affected players and relevant authorities in the event of a confirmed breach.

While srd9 takes every reasonable precaution to protect your data, no method of data transmission over the internet is entirely immune to risk. You are responsible for maintaining the security of your own srd9 account credentials. Do not share your password with any person, and contact [email protected] immediately if you suspect unauthorised access to your account.

12 Your Data Rights

As a data subject, you hold the following rights in relation to the personal data srd9 holds about you. To exercise any of these rights, please submit a written request to [email protected]. srd9 will respond within 30 calendar days of receiving a valid request:

• Right of access: You have the right to request a copy of the personal data srd9 holds about you, along with information about how it is being used and with whom it has been shared.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data held about you. Some corrections can be made directly within your account settings.
• Right to erasure: You may request that srd9 delete your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where there is no other lawful basis for continued processing. Note that certain data must be retained for legal compliance purposes even following an erasure request.
• Right to restriction: You have the right to request that srd9 temporarily restrict the processing of your data — for example, while the accuracy of the data is being disputed.
• Right to data portability: Where processing is based on your consent or a contract, and carried out by automated means, you may request your personal data in a structured, commonly used, machine-readable format.
• Right to object: You have the right to object to processing based on legitimate interests, including profiling. srd9 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to withdraw consent: Where processing is based solely on your consent (for example, marketing emails), you may withdraw that consent at any time with immediate effect for future processing.

srd9 will not charge a fee for handling data subject requests in ordinary circumstances. However, if a request is manifestly unfounded, repetitive, or excessive, srd9 reserves the right to charge a reasonable administrative fee or decline to act on the request, with written explanation provided to the requesting party.

13 Children & Minors

The srd9 Platform is strictly for adults aged 21 and above. srd9 does not knowingly collect, process, or retain personal data from any individual under the age of 21. Our registration process includes age verification steps specifically designed to prevent minors from accessing the Platform.

If srd9 discovers or is notified that personal data belonging to a person under the age of 21 has been collected, that data will be permanently deleted from our systems without delay, the associated account will be immediately and permanently closed, and any funds held in the account will be returned to the deposit source where feasible.

If you are a parent or guardian and believe that a minor in your care has registered an account or provided personal data to srd9, please contact us immediately at [email protected]. We will investigate and act promptly.

14 Third-Party Links

The srd9 Platform may contain references to third-party game providers and payment services. Where links to external websites or services are present, please note that srd9 has no control over the content, privacy practices, or security of those external destinations. This Privacy Policy applies solely to data processed by srd9 on the srd9 Platform and does not extend to any third-party websites or services.

srd9 recommends that you read the privacy policies of any third-party services you access, including your mobile banking provider (bKash, Nagad, Rocket, Upay) and any game studio whose games you play on the Platform, as those parties operate under their own independent data protection frameworks.

15 Policy Updates

srd9 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 Platform functionality. The updated Policy will be published on this page with a revised effective date clearly displayed at the top of the document.

Where changes to this Policy are material — meaning they significantly affect the way srd9 processes your personal data or alter your rights as a data subject — srd9 will provide advance notice to all registered players via the email address on file with their account, at least 14 calendar days before the changes take effect. Continued use of the Platform following the effective date of a revised Policy constitutes your acceptance of the updated terms.

We encourage you to review this Privacy Policy periodically to stay informed about how srd9 is protecting your information. If you have any questions about a specific change, please contact us at [email protected] before the effective date and we will be happy to clarify.

16 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way srd9 handles your personal data, please reach out to our support team using the contact details below. All privacy-related correspondence will be handled with strict confidentiality.

• Email: [email protected] (plain text — not a clickable link)
• Platform: https://srd9.io
• Support availability: 24 hours a day, 7 days a week, 365 days a year
• Languages: English support available at all times
• Response time: Privacy requests acknowledged within 48 hours; resolved within 30 calendar days