Privacy Policy of abc99999 — Your Data Protected by the LGPD

The controller of personal data collected by the platform abc99999 is the operating company of the abc99999.best website. As the data controller, it is responsible for all decisions regarding the processing of users' personal data, including the purpose, means, and duration of such processing.

A abc99999 has appointed a Data Protection Officer (DPO) to serve as the communication channel between the company, data subjects, and the National Data Protection Authority (ANPD). The DPO can be reached by email at privacidade@abc99999.best.

A abc99999 collects personal data at different points during the user's interaction with the platform. The data collected falls into the following categories:

Data provided directly by the user during registration:

• Full name — for identification and identity verification.
• CPF — for account uniqueness verification and regulatory compliance.
• Date of birth — for age verification (minimum 18 years).
• Email address — for platform communications and account recovery.
• Phone number — for account verification and security communications.
• Residential address — requested during identity verification.

Data generated through platform usage:

• Betting and gaming history — for account management and irregularity detection.
• Financial transaction history — deposits via Pix, boleto bancário, credit/debit card, PicPay, and Mercado Pago; and withdrawals via Pix.
• IP address and device data — for account security and fraud prevention.
• Browsing and session data — pages visited, session duration, and interactions on the platform.
• Communication preferences — marketing communications opt-in and opt-out.

Data collected by third parties:

• Identity verification data provided by authorized KYC (Know Your Customer) partners.
• Approximate geolocation data derived from IP address for eligibility verification.

The personal data collected by abc99999 are used exclusively for the following purposes:

Data will never be used for purposes other than those listed above without prior notice to the user and, where required, specific and unambiguous consent.

All personal data processing carried out by abc99999 is grounded in one of the legal bases set out in the LGPD. The main bases used are:

• Contract performance (art. 7, V): processing activities required to deliver the platform's services — account registration, bet processing, deposits and withdrawals via Pix or other methods.
• Legal or regulatory obligation (art. 7, II): processing required by law — identity verification, anti-money laundering compliance (Law No. 9,613/1998), protection of minors, and reporting to tax authorities.
• Legitimate interest (art. 7, IX): processing activities that serve the legitimate interests of abc99999 or third parties — including fraud prevention, platform security, and usage pattern analysis for service improvement — provided these do not override the fundamental rights and interests of the data subject.
• Consent (art. 7, I): marketing communications via email, mobile, or push notifications. Consent may be withdrawn at any time through the account settings panel or by contacting the DPO.

A abc99999 may share personal data with the following categories of recipients, strictly to the extent necessary for each purpose:

• Payment processors: partners that process transactions via Pix, boleto bancário, credit/debit card, PicPay, and Mercado Pago. These partners act as data processors and are contractually required to protect information in accordance with the LGPD.
• Identity verification (KYC) partners: companies specializing in CPF verification, document validation, and identity fraud prevention — used during the account verification process and for withdrawals above certain amounts.
• Casino game providers: providers of slots, live roulette, crash games, and other titles receive only the minimum data necessary to run the games — with no access to full financial details.
• Government and regulatory authorities: abc99999 may be legally required to share data with the Receita Federal, ANPD, COAF, or other competent authorities. Such sharing occurs only when mandated by law or court order.
• IT infrastructure providers: cloud computing, storage, and security services — all operating under contracts that include data protection clauses and, where applicable, subject to the LGPD.

International data transfers — when occasionally required for infrastructure service operations — are carried out in compliance with Chapter V of the LGPD, with adequate protection safeguards in place.

A abc99999 uses cookies and similar technologies to improve the user experience on the platform. The types of cookies used are:

• Strictly necessary cookies: essential for the basic operation of the platform — session authentication, login security, and language preferences. They cannot be disabled without affecting your ability to use the platform.
• Performance cookies: collect anonymous information about how users interact with the platform — most visited pages, load times, and technical errors — to improve overall site performance.
• Functional cookies: remember user preferences such as odds display settings, preferred language, and league filters — personalizing the experience without requiring reconfiguration on every visit.
• Analytical cookies: used internally by abc99999 for aggregated and anonymized behavioral analysis — with no individual user identification.

You can manage your cookie preferences through the banner shown on your first visit to the platform or through your browser settings. Disabling functional cookies may limit certain platform features, such as auto-fill forms and saved display preferences.

A abc99999 employs a robust set of technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, or improper disclosure:

• 256-bit SSL/TLS encryption across all communications between the user's device and the platform's servers.
• Encryption at rest for sensitive data stored in the database — including financial data and identity documents.
• Payment data tokenization — abc99999 does not store full credit card numbers; only encrypted tokens generated by our partner payment processors.
• Two-factor authentication (2FA) available to all users — strongly recommended for accounts with an active balance.
• Continuous 24/7 monitoring of access, transactions, and behavioral patterns for early detection of suspicious activity.
• Regular penetration testing and security audits conducted by internal teams and specialized external partners.
• Role-based internal access control — abc99999 staff members only access the data required for their specific roles.

Despite all measures in place, no system is completely immune to breaches. In the event of a security incident that may pose significant risk or harm to data subjects, the abc99999 will notify affected users and the ANPD as required by the LGPD.

The personal data collected by abc99999 are retained for as long as necessary to fulfill the purposes for which they were collected, in accordance with the retention periods established by Brazilian law:

• Registration and identity data: retained for as long as the account remains active and for a minimum of 5 years after closure, in accordance with tax and regulatory obligations.
• Financial transaction history: retained for a minimum of 5 years after each transaction is carried out, in accordance with the Law on Financial System Crimes (Law No. 7,492/1986) and COAF regulations.
• Betting records: retained for 2 years after each bet is placed, except in cases of ongoing dispute or investigation.
• Communication and support data: retained for 2 years for quality and compliance purposes.
• Security and access logs: retained for 6 months for audit and fraud prevention purposes.

Once minimum retention periods have been met, data is securely deleted or anonymized — meaning it can no longer be linked to the original owner. Requests for early deletion will be honored to the extent they do not conflict with legal retention obligations.

The LGPD guarantees data subjects a set of rights that abc99999 is committed to honoring in full. To exercise any of the rights listed below, submit a request to privacidade@abc99999.best with your full name, CPF, and a description of the right you wish to exercise:

• Confirmation and Access: confirm whether your data is being processed and receive a full copy of the information we hold about you.
• Correction: request the correction of incomplete, outdated, or inaccurate data. Basic registration details can be updated directly in your abc99999 dashboard.
• Anonymization, Blocking, or Deletion: request the anonymization of unnecessary data, the temporary suspension of processing, or the deletion of data processed in violation of the LGPD.
• Portability: receive your data in a structured, machine-readable format for transfer to another service provider.
• Sharing information: know which entities your data has been shared with and for what purpose.
• Consent withdrawal: withdraw consent given for processing based on that legal basis, without affecting any processing carried out prior to withdrawal.
• Objection: object to processing carried out on the basis of legitimate interest where there are relevant grounds relating to your particular situation.
• ANPD Complaint: file a complaint with the National Data Protection Authority (ANPD) if your request is not satisfactorily addressed by abc99999.

The response deadline for data subject requests is up to 15 business days from the receipt of the complete and verified request. In more complex cases, this deadline may be extended, with prior notice to the data subject.

A abc99999 does not collect or process personal data from individuals under 18 years of age. Use of the platform by minors is strictly prohibited, as stated in the Terms and Conditions and in accordance with Brazilian legislation governing sports betting.

The platform uses the following measures to prevent access by minors:

• Mandatory CPF verification at registration — which requires users to be of legal age.
• Explicit declaration of legal age during the account creation process.
• Identity verification with an official document for withdrawals above certain amounts.
• Monitoring of usage patterns that may indicate access by minors.

A abc99999 may update this Privacy Policy periodically to reflect changes in data processing practices, Brazilian legislation, or the services offered by the platform.

Material changes will be communicated via:

• Notification in the account dashboard the next time the user logs into the platform.
• Email sent to the registered address, with a summary of the changes and a link to the updated version.
• Informational banner on the platform's home page during the transition period.

The date of the last update to this Policy is always displayed at the top of this page. We recommend reviewing this document periodically. Continued use of the platform after any changes are published constitutes implicit acceptance of the updated terms.

For changes that involve new data processing or a change of purpose requiring consent, the abc99999 will request the user's explicit consent before initiating the new processing activity.

To exercise your rights as a data subject, ask questions about this Privacy Policy, or report any issue related to the processing of personal data by abc99999, please reach out through the channels below:

• Data Protection Officer (DPO): privacidade@abc99999.best — for formal data subject requests, complaints regarding data processing, and communications with the ANPD. Response time: up to 15 business days.
• General support: contato@abc99999.best or live chat on the platform, available 24/7 in Portuguese. For general privacy questions that do not require a formal DPO response, our support team typically replies within minutes.

This Privacy Policy is governed by Brazilian law, in particular the LGPD (Law No. 13,709/2018). Any dispute arising from this Policy shall be submitted to the jurisdiction of the competent Brazilian courts, with preference for the venue of the platform's registered address in Brazil.