suna101 Privacy Policy

When you register and use suna101, we collect personal data across several categories. The nature and volume of data collected depends on which services you access and the level of account verification you have completed. The categories of personal data we collect are as follows:

1.1 Registration & Identity Data

When you create a suna101 account, you provide us with your full legal name, date of birth, residential address (including district, division, and postcode), email address, and mobile number. This information is used to establish your identity, verify your age, and create your account record. Players based in Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, and Cox's Bazar are subject to the same data collection requirements.

1.2 KYC Verification Documents

To comply with our Know Your Customer (KYC) obligations, we may collect copies of government-issued photo identification (National Identity Card, passport, or driving licence), proof of address documents (utility bills, bank statements), and payment method verification evidence (bKash, Nagad, or Rocket wallet confirmation screenshots). These documents are stored securely and reviewed only by authorised compliance personnel.

1.3 Financial & Transaction Data

suna101 records all financial transactions conducted through your account, including deposits, withdrawals, bonus credits, and wager history. We record transaction amounts in Bangladeshi Taka (৳ BDT), timestamps, payment method references, and transaction status. We do not store full card numbers; only tokenised payment references are retained.

1.4 Usage & Behavioural Data

We collect data about how you interact with the suna101 platform, including pages visited, games launched, bet amounts and outcomes, session duration, device type, operating system, browser version, and IP address. This data is used to improve the platform, detect fraud, and personalise your experience where you have consented to personalisation.

1.5 Communications Data

If you contact our support team via live chat or email, we retain a record of that correspondence including the content of messages, timestamps, and resolution outcomes. This data is used for quality assurance, dispute resolution, and to maintain a service history for your account.

suna101 uses the personal data we collect for the following specific purposes. We do not use your data for any purpose not listed here without first obtaining your explicit consent or being required to do so by law.

• Account creation and management: To register your account, authenticate your identity at login, and maintain your account settings and preferences.
• Age and identity verification: To confirm that you are aged 18 or above and that the identity you have provided matches the documents submitted during KYC verification. 18+
• Payment processing: To process deposits and withdrawals via bKash, Nagad, Rocket, Upay, Visa, and Mastercard, and to maintain accurate financial records of all transactions in ৳ BDT.
• Service delivery: To provide access to cricket betting markets (BPL, IPL, T20 World Cup), casino games (slots, live tables, crash games), and all other features available on suna101.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, account takeovers, and other criminal or harmful behaviour on the platform.
• Responsible gaming compliance: To monitor gambling behaviour for signs of problem gambling, enforce deposit limits, process self-exclusion requests, and implement responsible gaming tools in line with our Responsible Gaming policy.
• Customer support: To respond to your enquiries, resolve disputes, and maintain a record of your support history.
• Legal and regulatory compliance: To fulfil our obligations under applicable anti-money laundering, counter-terrorism financing, and data protection laws.
• Marketing communications (consent-based only): To send you promotional offers, bonus notifications, and updates about cricket betting events where you have explicitly opted in to marketing communications. You may opt out at any time.
• Platform improvement and analytics: To analyse aggregated usage data and improve the performance, design, and content of the suna101 platform.

suna101 processes personal data on one or more of the following legal grounds, depending on the specific processing activity:

• Contractual necessity: Processing required to fulfil the contract between suna101 and you as a registered player — including account creation, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable laws, including anti-money laundering regulations, age verification requirements, and financial record-keeping obligations.
• Legitimate interests: Processing carried out to pursue the legitimate interests of suna101, including fraud detection, platform security, responsible gaming monitoring, and service improvement — where these interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent — in particular, the sending of marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Where processing is based on legitimate interests, suna101 conducts a balancing test to ensure that our interests do not override your fundamental rights. If you wish to understand the outcome of a specific balancing test, you may contact us at support@suna101.

suna101 does not sell, rent, or trade your personal data to third parties for commercial purposes. We share personal data only in the limited circumstances described below, and only with parties that are contractually required to handle your data securely and in accordance with applicable data protection standards.

4.1 Payment Service Providers

To process your deposits and withdrawals, we share transaction data with our payment partners including bKash, Nagad, Rocket, Upay, Visa, and Mastercard. Each of these providers operates under its own privacy policy and is independently responsible for its data processing activities. suna101 shares only the minimum data necessary to complete each transaction.

4.2 Game Providers

When you launch a casino game on suna101, a secure session token is shared with the relevant third-party game studio (such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, or Ezugi) to authenticate your session and record game outcomes. These providers do not receive your full identity data; they receive only the session reference and your suna101 player ID.

4.3 Identity Verification Services

suna101 may engage third-party KYC and identity verification providers to assist with the validation of documents submitted during account verification. These providers are bound by strict data processing agreements and may not use your identity data for any purpose other than verification on our behalf.

4.4 Regulatory and Law Enforcement Authorities

suna101 may be required by law to disclose personal data to government authorities, regulatory bodies, or law enforcement agencies. We will notify you of any such disclosure request where we are legally permitted to do so. We will not disclose data beyond what is strictly required by the applicable legal obligation.

4.5 Corporate Transfers

In the event of a merger, acquisition, or sale of all or part of suna101's business, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify you in advance of any such transfer and your rights under this Privacy Policy will continue to apply.

suna101 uses cookies and similar tracking technologies to operate and improve the platform. A cookie is a small text file stored on your device by your browser when you visit our site. The cookies we use fall into the following categories:

suna101 does not use third-party advertising cookies, retargeting pixels, social media tracking scripts, or any cross-site tracking technology. Analytics data is collected using first-party tools only and is not shared with external analytics vendors.

You can manage or delete cookies through your browser settings at any time. Disabling essential cookies will prevent you from logging in to suna101 and using key platform features. Disabling functional or analytics cookies will not prevent access but may affect the quality of your experience.

suna101 retains your personal data for as long as your account remains active, and for specified additional periods after account closure as required by law or our internal compliance policies. The retention periods applicable to each data category are summarised below:

• Account and identity data: Retained for the lifetime of your account, plus a minimum of 5 years following account closure to meet anti-money laundering record-keeping requirements.
• Transaction and financial records: Retained for a minimum of 7 years from the date of each transaction, in accordance with financial regulations applicable to the platform.
• KYC verification documents: Retained for the duration of the account plus 5 years post-closure. Original document images are deleted once verification is confirmed, and only the verification outcome and reference are retained where possible.
• Betting and game history: Retained for 5 years from the date of each gaming session to support dispute resolution and regulatory audit requirements.
• Support communications: Retained for 3 years from the date of the interaction, or longer if the communication relates to an ongoing dispute or investigation.
• Marketing consent records: Retained for the duration of your account plus 3 years, to maintain an auditable record of consent decisions and opt-out requests.
• Analytics and usage data: Aggregated and anonymised after 13 months. Anonymised data is not subject to retention limits as it can no longer be linked to an identifiable individual.

When data is no longer required and the applicable retention period has expired, suna101 permanently deletes or irreversibly anonymises the data using secure destruction methods. Where physical document copies exist, these are destroyed via certified secure shredding processes.

As a player on suna101, you hold the following rights in relation to the personal data we hold about you. To exercise any of these rights, please contact our data team at support@suna101 with the subject line "Data Rights Request" and your registered email address. We will respond within 30 calendar days of receiving a valid request.

• Right of Access: You have the right to request a copy of all personal data suna101 holds about you, together with information about how it is being used (commonly known as a Subject Access Request or SAR).
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected without undue delay.
• Right to Erasure ("Right to be Forgotten"): You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent, or where you object to processing and there are no overriding legitimate grounds. Note that this right may be limited where we are required to retain data by law (e.g., for AML record-keeping).
• Right to Restriction of Processing: You may request that suna101 restrict the processing of your data in certain circumstances — for example, while a dispute about the accuracy of the data is being resolved.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, machine-readable format (such as CSV or JSON), and to have that data transmitted directly to another controller where technically feasible.
• Right to Object: You have the right to object to processing based on legitimate interests or carried out for direct marketing purposes. Where you object to direct marketing, we will cease processing your data for that purpose immediately.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

suna101 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security framework includes the following controls:

• Transport Layer Security (TLS 1.2+): All data transmitted between your browser or mobile device and the suna101 platform is encrypted using TLS 1.2 or higher. This applies to all pages, including the cashier, account settings, and game interfaces.
• At-rest encryption: Sensitive data fields stored in our databases — including identity information, payment references, and KYC document metadata — are encrypted at rest using AES-256 encryption.
• Access controls: Access to production systems containing personal data is restricted to authorised personnel only, using role-based access controls, multi-factor authentication, and audit logging of all access events.
• Network security: Our infrastructure is protected by web application firewalls (WAF), intrusion detection systems (IDS), and distributed denial-of-service (DDoS) mitigation to prevent unauthorised access attempts.
• Password security: Passwords are stored using industry-standard one-way hashing algorithms with salting. suna101 staff can never view your plaintext password. We recommend using a strong, unique password for your suna101 account.
• Security testing: suna101 conducts regular vulnerability assessments and penetration testing of its platform infrastructure to identify and remediate security weaknesses before they can be exploited.
• Incident response: In the event of a confirmed data breach affecting your personal data, suna101 will notify affected players and relevant authorities within the timeframe required by applicable law, providing details of the breach and the steps taken to contain it.

While suna101 takes all reasonable precautions to protect your data, no system connected to the internet can be guaranteed to be 100% secure. You are responsible for maintaining the confidentiality of your account password and for logging out of your account after each session, particularly when using shared devices.

suna101 is strictly an adult-only platform. Access to our services is prohibited for individuals under the age of 18. 18+

We do not knowingly collect, store, or process personal data from individuals under the age of 18. If, following an identity verification check, we discover that a player has registered on suna101 while under the age of 18, we will:

• Immediately suspend and permanently close the account.
• Void and forfeit any balance, winnings, or bonuses associated with the account.
• Delete all personal data associated with the underage account as swiftly as technically possible, subject to any legal retention obligations.
• Report the matter to relevant authorities where required by applicable law.

If you are a parent or guardian and you believe that a person under 18 in your care has registered on suna101 or has accessed our platform, please contact our support team immediately at support@suna101. We will investigate and take all necessary action promptly. We also recommend using parental control software to restrict access to gambling websites on shared or family devices.

suna101 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing activities, applicable law, or platform features. When we make material changes to this Privacy Policy, we will notify registered players via email at least 14 days before the changes take effect. For minor or clarificatory changes, we will update the "Last Updated" date at the top of this page without individual notification.

Continued use of the suna101 platform following notification of a Privacy Policy update constitutes your acceptance of the revised policy. If you do not agree with any changes to this Privacy Policy, you have the right to close your account prior to the changes taking effect by contacting our support team.

The current version of this Privacy Policy supersedes all prior versions. The version history is available on request by contacting support@suna101.

Data Controller Contact Details

If you have any questions, concerns, or complaints about this Privacy Policy or the way suna101 handles your personal data, please contact our data protection team:

• Email: support@suna101 (subject line: "Privacy Enquiry")
• Live Chat: Available 24/7 on the suna101 website — response under 2 minutes
• Response time (email): Within 3 business days for general enquiries; within 30 calendar days for formal data rights requests
• Operating hours: All times Bangladesh Standard Time (BST, UTC+6)

Last Updated: January 2026. This Privacy Policy applies to all players registered on suna101. 18+