Privacy Policy — soan101

soan101 collects personal data from players in order to provide, operate, and improve the services available on our platform. We collect only the data that is necessary for these defined purposes. The categories of personal data we collect are described below.

1.1 Information You Provide Directly

When you register an account, complete your profile, submit KYC documents, or contact our support team, you may provide us with the following personal information:

• Identity data: Full legal name, date of birth, nationality, and National Identity Card (NID) or passport number
• Contact data: Email address, mobile phone number (Bangladesh number), and residential address
• Financial data: Payment method details including bKash wallet number, Nagad number, Rocket number, Upay number, or bank account details for Dutch-Bangla Bank, City Bank, BRAC Bank, or Islami Bank
• Account credentials: Username and encrypted password (passwords are stored in hashed form and are never visible to soan101 staff)
• KYC documents: Scanned or photographed copies of government-issued identification and proof of address documents submitted for account verification
• Communications data: Records of any communications you send to soan101 via email, live chat, or support ticket systems

1.2 Information Collected Automatically

When you access and use the soan101 platform, certain technical and behavioural data is collected automatically through your browser and device:

• Device data: Device type, operating system, browser type and version, screen resolution, and device identifiers
• Network data: IP address, approximate geographic location derived from IP address, and internet service provider information
• Usage data: Pages visited, features accessed, time spent on each page, search queries within the platform, game sessions started and completed, and betting history
• Session data: Login timestamps, session duration, and logout events
• Cookie and tracking data: Data collected via cookies and similar technologies as described in Section 4 of this Privacy Policy

1.3 Information From Third Parties

In certain circumstances, soan101 may receive personal data about you from third parties. These circumstances include identity and age verification checks conducted through third-party KYC service providers, fraud prevention checks run through industry-standard AML screening tools, and payment processing confirmations received from bKash, Nagad, Rocket, Upay, and our banking partners. Information received from third parties is treated with the same level of care and subject to the same data protection standards as information you provide directly.

soan101 uses the personal data we collect for specific, legitimate purposes. We do not use your data in ways that are incompatible with the purposes for which it was originally collected. The table below summarises the primary purposes for which your data is used and the legal basis for each use.

2.1 Marketing Communications

soan101 may send you promotional emails, SMS notifications, or in-platform messages about bonus offers, upcoming BPL or T20 promotions, seasonal offers tied to Eid or Pohela Boishakh, and other platform news — but only where you have given us your explicit consent to do so at the point of registration or via your account notification preferences. You may withdraw your consent to receive marketing communications at any time by updating your preferences in your account settings or by contacting our support team.

2.2 Automated Decision-Making

In certain limited cases, soan101 uses automated processing to make decisions about your account. This includes automated fraud detection algorithms that may flag or temporarily suspend an account where suspicious activity is detected, and automated responsible gaming tools that may trigger deposit limit prompts or cooling-off suggestions based on your play patterns. Where an automated decision has a significant effect on your account, you have the right to request a human review of that decision by contacting our support team.

soan101 does not sell, rent, or trade your personal data. We share your information only in the specific, limited circumstances described in this section, and always with appropriate data protection safeguards in place.

3.1 Service Providers and Data Processors

To operate the soan101 platform effectively, we engage a limited number of trusted third-party service providers who process data on our behalf and under our instructions. These include:

• Payment processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, and Islami Bank — to facilitate the processing of deposits and withdrawals in Bangladeshi Taka (৳)
• KYC and identity verification providers: Third-party services that assist in verifying your identity, age, and document authenticity as part of the account verification process
• AML screening providers: Services used to screen player accounts and transactions against watchlists and sanction databases in compliance with anti-money laundering obligations
• Game software providers: Including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi, who supply the game content and RNG systems and may receive limited session data necessary to deliver game functionality
• IT infrastructure and hosting providers: Secure server and cloud infrastructure providers who host the soan101 platform and its databases
• Analytics providers: Tools used to analyse aggregate, anonymised platform usage data to improve the user experience

All third-party service providers engaged by soan101 are contractually required to process your data only for the specific purpose for which it was shared, to maintain appropriate security standards, and not to use it for any independent commercial purpose.

3.2 Legal and Regulatory Disclosure

soan101 may be required to disclose your personal data to law enforcement agencies, government bodies, courts, or other regulatory authorities where required to do so by applicable law, court order, or where disclosure is necessary to prevent fraud, money laundering, or other serious criminal activity. We will, where legally permitted, notify you of any such disclosure request before complying with it.

3.3 Business Transfers

In the event that soan101 undergoes a merger, acquisition, restructuring, or sale of all or part of its business assets, your personal data may be transferred to the acquiring entity as part of that transaction. In such circumstances, you will be notified via the email address registered to your account and given the opportunity to exercise your data rights before the transfer is completed.

soan101 uses cookies and similar tracking technologies to provide core platform functionality, remember your preferences, and understand how the platform is used. This section explains what types of cookies we use, what they do, and how you can manage them.

4.1 What Are Cookies?

Cookies are small text files placed on your device by a website when you visit it. They are widely used to make websites function correctly, improve efficiency, and provide information to the platform operators. Cookies do not contain malicious code and cannot access other files on your device.

4.2 Types of Cookies Used by soan101

4.3 Managing Your Cookie Preferences

You can control and manage cookies through your web browser settings. Most modern browsers allow you to refuse or delete cookies, or to be notified when a cookie is being set. Please note that disabling essential cookies will impair the functionality of the soan101 platform and may prevent you from logging in or accessing certain features. Instructions for managing cookies are available in the help documentation of all major browsers including Chrome, Firefox, Safari, and Edge.

4.4 Local Storage and Similar Technologies

In addition to cookies, soan101 may use browser local storage and session storage to retain small amounts of data on your device for the purpose of improving platform performance and maintaining game state. This data is stored locally on your device and is not transmitted to soan101 servers independently of your normal platform activity.

soan101 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, to comply with applicable legal obligations, and to resolve disputes or enforce agreements. The specific retention periods applied to different categories of data are set out below.

5.1 Active Account Data

While your soan101 account is active, we retain all personal data associated with your account, including identity data, contact data, financial data, and betting history. This data is necessary to operate your account, process transactions, provide customer support, and comply with responsible gaming and anti-money laundering obligations.

5.2 Data After Account Closure

Following the closure of a soan101 account — whether initiated by you or by soan101 — we retain certain categories of personal data for the periods specified below:

• Identity and KYC documents: Retained for a minimum of 5 years from the date of account closure, in compliance with AML record-keeping obligations
• Transaction and financial records: Retained for a minimum of 5 years from the date of each transaction
• Betting history and session logs: Retained for 2 years from the date of account closure for responsible gaming and dispute resolution purposes
• Communications records: Retained for 2 years from the date of the most recent communication
• Marketing consent records: Retained for 3 years from the date consent was granted or withdrawn, to demonstrate compliance

5.3 Anonymisation

Where personal data is no longer required for any of the purposes described in this Privacy Policy and its retention period has expired, soan101 will either securely delete the data or irreversibly anonymise it so that it can no longer be linked to you as an individual. Anonymised data may be retained indefinitely for aggregate statistical analysis.

soan101 takes the security of your personal data seriously and has implemented a range of technical and organisational measures designed to protect your information against unauthorised access, loss, alteration, or disclosure.

6.1 Technical Security Measures

• SSL/TLS encryption: All data transmitted between your device and soan101 is encrypted using SSL/TLS protocols, preventing interception in transit
• Password hashing: Passwords are stored using industry-standard one-way hashing algorithms; they are never stored in plain text and are never visible to soan101 personnel
• Firewalls and intrusion detection: Our server infrastructure is protected by firewalls and continuous intrusion detection systems that monitor for unusual access patterns
• Access controls: Access to systems holding personal data is restricted to authorised personnel only, using role-based access controls and multi-factor authentication for administrative systems
• Regular security audits: soan101 conducts regular internal and third-party security assessments to identify and remediate vulnerabilities in the platform and its underlying infrastructure

6.2 Organisational Security Measures

Beyond technical controls, soan101 maintains a set of internal data protection policies and practices that govern how staff handle player data. These include mandatory data protection training for all staff who have access to personal data, strict policies on the use of personal data outside of designated secure systems, and a formal incident response procedure that governs how the organisation responds to data security events.

6.3 Your Role in Data Security

While soan101 takes extensive measures to protect your data, the security of your account also depends on the steps you take to protect your own login credentials. You should use a strong and unique password for your soan101 account, never share your login details with anyone, log out of your account when using a shared or public device, and contact our support team immediately if you suspect any unauthorised access to your account.

As a player on soan101, you have a number of rights with respect to the personal data we hold about you. These rights are described below, along with guidance on how to exercise them.

7.1 Right of Access

You have the right to request a copy of the personal data that soan101 holds about you. This is sometimes referred to as a Subject Access Request (SAR). Upon receipt of a valid request, we will provide you with a summary of the data we hold, the purposes for which it is processed, and any third parties with whom it has been shared. We will respond to access requests within 30 days of receipt.

7.2 Right to Rectification

If any of the personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it. You may update certain information directly within your soan101 account settings. For changes to identity data or KYC-verified information, please contact our support team, as additional verification may be required before amendments are made.

7.3 Right to Erasure

You have the right to request the deletion of your personal data in certain circumstances — for example, where the data is no longer necessary for the purpose for which it was collected, or where you have withdrawn consent and there is no other legal basis for processing. This right is subject to certain limitations where data must be retained to comply with legal obligations, such as AML record-keeping requirements.

7.4 Right to Restrict Processing

In certain circumstances, you have the right to request that soan101 restricts the processing of your personal data — for example, while a dispute about the accuracy of the data is being resolved, or where you have objected to processing and a determination is pending.

7.5 Right to Data Portability

Where data is processed on the basis of your consent or contractual necessity, you have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that it be transferred to another data controller where technically feasible.

7.6 Right to Object

You have the right to object at any time to the processing of your personal data for direct marketing purposes. You also have the right to object to processing carried out on the basis of legitimate interests, though this right is subject to a balancing assessment against soan101's legitimate grounds for processing.

7.7 Exercising Your Rights

To exercise any of the rights described above, please contact the soan101 data team at support@soan101 with the subject line "Data Rights Request". Please include your registered account username and a brief description of the right you wish to exercise. We will acknowledge your request within 5 business days and aim to fulfil it within 30 calendar days. In complex cases, the response period may be extended by a further 30 days, in which case we will notify you of the extension and the reason for it.

soan101 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, changes in applicable law, or improvements to our platform and services. All updates will be published at the /privacy-policy page and will take effect immediately upon publication, unless a later effective date is specified.

8.1 Notification of Material Changes

Where a change to this Privacy Policy is material — meaning it significantly affects how we collect, use, or share your personal data — soan101 will notify registered players via their registered email address at least 14 days before the change takes effect. Your continued use of soan101 after the effective date of a revised Privacy Policy constitutes your acknowledgement of the updated terms. If you do not agree with the changes, you should stop using the platform and contact us to close your account.

8.2 Version History

The current version of this Privacy Policy is effective as of 1 January 2026. Previous versions of the Privacy Policy are available upon request by contacting our support team. Each published version is archived and timestamped to provide a clear record of how our data practices have evolved over time.

8.3 Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way soan101 handles your personal data, please contact our support team. We are available 24 hours a day, 7 days a week, and all privacy-related enquiries will be escalated to our data protection team for review.

Email: support@soan101 — please use the subject line "Privacy Enquiry" to ensure your message reaches the correct team promptly. We aim to acknowledge all privacy-related correspondence within one business day (Bangladesh Standard Time, UTC+6) and to provide a substantive response within 10 business days.