Privacy Policy — sono101

1. Data Controller Information

sono101 acts as the data controller for all personal information collected through the platform. As data controller, sono101 determines the purposes and means by which your personal data is processed. All data protection queries, access requests, correction requests, and deletion requests should be directed to the sono101 data protection contact at support@sono101 with the subject line "Data Privacy Request".

This Privacy Policy applies to all users of the sono101 website and associated mobile interfaces, regardless of the device used to access the platform. It applies to all data collected during the registration process, during ongoing platform use, and during the account closure process. It does not apply to third-party websites or services that may be linked to or from the sono101 platform — those entities operate under their own privacy policies.

sono101 may update this Privacy Policy from time to time to reflect changes in platform functionality, data processing practices, or applicable regulatory requirements. The effective date shown at the top of this page reflects the date on which the most recent revision came into force. Where changes are material, sono101 will notify registered players by email prior to the changes taking effect. Continued use of the platform after the effective date of any revised policy constitutes acceptance of the revised terms.

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2. Data We Collect

sono101 collects personal data through several channels: directly from you during registration and account management; automatically through your use of the platform; and from third-party service providers involved in identity verification or payment processing. The categories of data we collect include the following.

2.1 Registration and Identity Data

When you create an account on sono101, we collect: your full legal name; date of birth; residential address (including city, division, and postcode); email address; Bangladeshi mobile phone number; and, where required for KYC verification, copies of government-issued identity documents such as your National Identity Card (NID) , passport, or driving licence, and proof of address documentation.

2.2 Financial and Transaction Data

To process deposits and withdrawals, sono101 collects details of the payment methods you use, including your bKash, Nagad, Rocket, or Upay mobile wallet numbers, bank account details where applicable, and transaction records. Full card numbers and payment credentials are never stored directly on sono101's servers — these are handled exclusively by our PCI-compliant payment processing partners.

2.3 Betting and Gaming Activity Data

We maintain records of all betting and gaming activity associated with your account. This includes: sports bets placed (markets, selections, stakes, odds, outcomes); casino game sessions (game titles, bet amounts, session duration, wins and losses); bonus claims and wagering progress; and account balance history. This data is used for account management, dispute resolution, responsible gaming monitoring, and regulatory compliance.

2.4 Technical and Device Data

When you access sono101, our systems automatically collect certain technical information, including: your IP address; device type, operating system, and browser version; session timestamps and duration; pages visited and features used within the platform; and referring URLs. This data helps us maintain platform security, detect fraudulent access patterns, and improve the overall user experience.

2.5 Communications Data

If you contact sono101's customer support team via live chat, email, or any other supported channel, we retain records of that communication, including the content of messages, timestamps, and the support agent's responses. These records are used for quality assurance, dispute resolution, and staff training purposes.

Data Category	Examples	Primary Purpose
Identity Data	Name, NID, date of birth, address	KYC verification, AML compliance
Financial Data	bKash number, transaction history	Payment processing, fraud detection
Gaming Activity	Bets placed, game sessions, outcomes	Account management, responsible gaming
Technical Data	IP address, device type, session logs	Security, fraud prevention, analytics
Communications Data	Support chat transcripts, emails	Dispute resolution, quality assurance

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3. How We Use Your Data

sono101 processes your personal data only where a lawful basis exists for doing so. The following describes the primary purposes for which we use your data and the corresponding legal basis for each processing activity.

3.1 Account Management and Service Delivery

We use your registration and identity data to create and maintain your player account, verify your eligibility to use the platform (including age verification), authenticate your identity at login, and provide you with access to sports betting, casino, and slot game services. This processing is necessary for the performance of the contract between you and sono101.

3.2 Payment Processing

Your financial data is used to process deposit and withdrawal transactions via bKash, Nagad, Rocket, Upay, and supported banking partners. We also use transaction data to detect and prevent payment fraud and unauthorised account access. This processing is necessary for the performance of your contract with sono101 and for the pursuit of our legitimate interest in preventing financial crime.

3.3 Legal and Regulatory Compliance

sono101 is required to process certain categories of personal data to comply with anti-money laundering (AML) obligations, Know Your Customer (KYC) requirements, and other applicable regulatory obligations. This processing is necessary for compliance with legal obligations to which sono101 is subject. Data processed for this purpose may include identity documents, transaction records, and source-of-funds information.

3.4 Responsible Gaming Monitoring

We use gaming activity data, including betting frequency, session duration, deposit patterns, and loss tracking, to monitor for signs of problem gambling and to facilitate the responsible gaming tools available in your account settings. Where our systems identify patterns consistent with harmful gambling behaviour, we may contact you proactively or apply protective measures such as temporary deposit limits. This processing is carried out in pursuit of our legitimate interest in player welfare and our commitment to responsible gaming standards.

3.5 Marketing Communications

Where you have provided explicit consent to receive marketing communications, sono101 may use your email address and mobile number to send promotional offers, bonus notifications, and platform updates. You may withdraw your consent to marketing communications at any time by contacting support or by using the unsubscribe mechanism included in all marketing emails. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

3.6 Platform Security and Fraud Prevention

Technical and device data — including IP addresses, session logs, and device fingerprints — is used to identify and prevent unauthorised account access, detect multi-accounting, identify bonus abuse patterns, and protect the integrity of the platform. This processing is carried out in pursuit of sono101's legitimate interest in maintaining a secure and fair gaming environment.

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4. Data Sharing & Third Parties

sono101 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share personal data only in the limited circumstances described below, and only to the extent strictly necessary for the relevant purpose.

4.1 Payment Service Providers

To process your deposits and withdrawals, we share necessary financial data with our approved payment partners, which include bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, and BRAC Bank. Each of these partners operates under its own data processing obligations and privacy policies. sono101 requires all payment partners to maintain appropriate technical and organisational security measures.

4.2 Identity Verification and KYC Providers

To verify your identity and comply with KYC and AML obligations, sono101 may share identity documents and personal information with contracted third-party identity verification service providers. These providers are bound by strict data processing agreements and may not use your data for any purpose other than providing verification services to sono101.

4.3 Fraud Prevention and Security Services

We may share technical data such as IP addresses, device identifiers, and transaction patterns with specialist fraud prevention and cybersecurity service providers to detect and prevent fraudulent activity on the platform. Such sharing is subject to data processing agreements that restrict the provider's use of the data.

4.4 Legal and Regulatory Disclosures

sono101 may disclose personal data to law enforcement authorities, regulatory bodies, or other competent government agencies where required to do so by applicable law, court order, or where we have a reasonable belief that such disclosure is necessary to prevent serious harm, detect or investigate criminal activity, or protect the rights and safety of sono101, its players, or the general public.

4.5 Business Transfers

In the event that sono101 undergoes a merger, acquisition, restructuring, or sale of all or part of its assets, your personal data may be transferred to the relevant successor entity as part of that transaction. Where such a transfer occurs, sono101 will take reasonable steps to ensure that your data continues to be protected in a manner consistent with this Privacy Policy, and will notify affected players by email prior to the transfer taking effect.

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5. Cookies & Tracking Technologies

sono101 uses cookies and similar tracking technologies to ensure the platform functions correctly, to maintain your session security, and to understand how the platform is used. A cookie is a small text file placed on your device by our web server when you access the platform. The following categories of cookies are used.

5.1 Strictly Necessary Cookies

These cookies are essential for the operation of the platform. They include session authentication cookies that keep you logged in during your visit, security cookies that help detect and prevent fraudulent access, and cookies that remember your in-session preferences such as language settings. These cookies cannot be disabled without rendering the platform non-functional. No consent is required to place these cookies.

5.2 Analytical and Performance Cookies

sono101 uses analytics cookies to collect anonymised or pseudonymised data about how players interact with the platform — including which pages are most visited, where users spend the most time, and where errors occur. This information is used to improve platform performance and user experience. Analytical cookies do not identify you personally.

5.3 Functional Cookies

Functional cookies remember your preferences and settings between sessions — such as your preferred display language, last-visited sport or game category, and notification preferences. Disabling these cookies may result in a less personalised experience but will not prevent you from using core platform features.

5.4 Managing Cookies

You can manage, restrict, or delete cookies through your browser's built-in settings. Most browsers allow you to refuse new cookies, delete existing cookies, and receive notifications when new cookies are placed. Please note that restricting certain cookies may impair the functionality of the sono101 platform. Instructions for managing cookies in commonly used browsers are available through each browser provider's support documentation.

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6. Data Retention

sono101 retains personal data for as long as is necessary to fulfil the purpose for which it was collected, or for as long as required by applicable law or regulation. The following general retention periods apply.

• Active account data: Retained for the full duration of your account and for a minimum of five years after account closure, in accordance with AML and record-keeping obligations.
• Transaction and financial records: Retained for a minimum of six years from the date of each transaction, in line with standard financial record-keeping practice.
• KYC and identity documents: Retained for a minimum of five years after account closure or the date of the last regulated transaction, whichever is later.
• Support communications: Retained for three years from the date of the last communication, or longer where the communication relates to an open dispute or regulatory inquiry.
• Technical and device data: Typically retained for 12 months from collection, unless retained longer in connection with a security investigation or fraud case.
• Marketing preferences and consent records: Retained for the duration of your account, plus three years after account closure, to document the basis on which marketing communications were or were not sent.

When retention periods expire, personal data is securely deleted or anonymised in a manner that prevents reconstruction of the original data. Anonymised aggregated data (for example, platform-wide statistical trends) may be retained indefinitely as it can no longer be linked to an identifiable individual.

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7. Your Rights & Choices

As a player whose personal data is processed by sono101, you hold a number of rights in respect of that data. sono101 is committed to facilitating the exercise of these rights promptly and without undue restriction. To exercise any of the rights described below, contact sono101's support team at support@sono101 with the subject line "Data Privacy Request", providing sufficient information to verify your identity.

7.1 Right of Access

You have the right to request a copy of the personal data that sono101 holds about you, along with information about how that data is processed. We will respond to access requests within 30 days of receipt of a verified request. Data will be provided in a commonly used, machine-readable format where technically feasible.

7.2 Right to Correction

If you believe that any personal data we hold about you is inaccurate, incomplete, or out of date, you have the right to request that we correct it. For standard account information such as email address, phone number, or residential address, corrections may be made directly within your account settings. Where correction of identity documents or date of birth is required, additional verification may be requested.

7.3 Right to Erasure

You may 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 withdraw consent and no other lawful basis for processing exists. Please note that sono101 may be unable to fulfil erasure requests in full where data must be retained to comply with legal obligations such as AML record-keeping requirements. We will notify you of any data that cannot be erased and explain the reason.

7.4 Right to Restrict Processing

You have the right to request that sono101 restricts the processing of your personal data in certain circumstances — for example, while the accuracy of data you have disputed is being verified, or where you have objected to processing and we are assessing that objection. During a restriction period, we will continue to store your data but will not actively process it for other purposes.

7.5 Right to Object to Marketing

You have the absolute right to object to the use of your personal data for direct marketing purposes at any time. To opt out of marketing communications from sono101, contact support or use the unsubscribe link included in any marketing email. Opting out of marketing will not affect your ability to receive transactional or account-related communications that are necessary for the operation of your account.

7.6 Complaints

If you believe that sono101 has handled your personal data in a manner that does not comply with this Privacy Policy or applicable data protection principles, you are encouraged to contact us in the first instance so that we can investigate and attempt to resolve your concern. Complaints should be submitted to support@sono101 with the subject line "Data Privacy Complaint". We aim to acknowledge all complaints within five business days and to provide a substantive response within 30 days.

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8. Data Security

sono101 takes the security of your personal data seriously and implements a range of technical and organisational measures to protect it against unauthorised access, accidental loss, disclosure, alteration, or destruction. These measures include the following.

• SSL/TLS encryption: All data transmitted between your device and our platform is encrypted in transit using industry-standard Transport Layer Security (TLS) protocols.
• Password hashing: Account passwords are stored using strong one-way cryptographic hashing algorithms. sono101 never stores passwords in plain text and cannot retrieve your password — only reset it.
• Access controls: Access to personal data within sono101's internal systems is restricted to employees and contractors who require access to fulfil their specific job functions. Access is granted on a least-privilege basis and subject to regular review.
• Payment tokenisation: Sensitive payment credentials (such as mobile wallet identifiers) are tokenised in our systems. Raw financial credentials are never stored directly on sono101's servers.
• Fraud detection systems: Automated systems continuously monitor platform activity for patterns indicative of account compromise, unauthorised access attempts, or fraudulent transactions.
• Regular security reviews: sono101 conducts periodic internal reviews of its data processing systems and security controls to identify and remediate vulnerabilities.

While sono101 implements robust security measures, no online platform can guarantee absolute security against all possible threats. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, sono101 will notify affected players without undue delay and take all appropriate steps to contain the breach and mitigate its impact.

Players are reminded that account security also depends on their own actions. You should choose a strong, unique password for your sono101 account, never share your login credentials with anyone, and contact support immediately if you suspect that your account has been accessed without your authorisation. For further details about our platform rules and user obligations, please refer to the Terms & Conditions page.