Privacy Policy – How l89l Collects, Uses, and Protects Your Data

1 Introduction

l89l ("the Platform", "we", "us", "our") is committed to protecting the privacy and personal data of every player who accesses or uses the l89l online casino and sports betting platform. This Privacy Policy sets out the lawful basis on which we collect and process personal data, the categories of data we hold, and the rights available to you as a data subject.

This policy applies to all users of the l89l platform, including registered account holders, visitors who browse the site without registering, and individuals who contact our customer support team. It covers data collected through the l89l website at https://l89l.io, its mobile-optimised interface, and any associated communication channels including live chat and email.

We process personal data only for the purposes described in this policy and in accordance with applicable data protection principles. We do not sell, rent, or trade your personal data to third parties for their independent marketing purposes. Our approach to data is built on the principles of transparency, data minimisation, purpose limitation, and security.

2 Personal Data We Collect

l89l collects personal data that is necessary to provide you with a safe, compliant, and high-quality online gaming experience. The categories of personal data we may collect include, but are not limited to, the following:

2.1 Identity & Contact Data

• Full legal name as it appears on your government-issued identity document;
• Date of birth (used to verify the 21+ age requirement);
• Residential address, city, and postal code;
• Email address and mobile phone number;
• Copies of identity documents submitted during KYC verification (National ID card, passport, or driving licence).

2.2 Account & Transaction Data

• Username and encrypted password hash;
• Account registration date and last login timestamp;
• Deposit and withdrawal history, including amounts in Bangladeshi Taka (৳ BDT), payment method used, and transaction reference numbers;
• Bonus and promotion history, including wager records and bonus balance movements;
• Full betting and gaming history across all l89l products.

2.3 Technical & Usage Data

• IP address and approximate geolocation at the time of login;
• Device type, operating system, browser version, and screen resolution;
• Session duration, pages visited, and click-path data within the platform;
• Error logs and crash reports generated during platform use.

2.4 Communication Data

• Live chat transcripts between you and the l89l support team;
• Email correspondence sent to or received from l89l;
• Records of any complaints or dispute submissions.

3 How We Collect Your Data

l89l collects personal data through the following channels:

• Direct submission: Information you provide when registering an account, completing KYC verification, making a deposit, or contacting customer support;
• Automated collection: Technical data collected automatically when you access the platform, including IP address, device identifiers, and browser fingerprint via server logs and cookies;
• Payment providers: Transaction confirmation data shared by payment processors such as bKash, Nagad, Rocket, and Upay when you make a deposit or withdrawal;
• Third-party verification services: Identity and age verification data returned by our KYC service providers when processing your identity documents;
• Game providers: Aggregated game session and outcome data shared by our licensed game studio partners including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Ezugi.

4 Purpose & Legal Basis for Processing

We process your personal data only where we have a clear lawful basis and a defined legitimate purpose. The table below summarises the primary purposes for which l89l processes personal data and the corresponding legal basis for each:

Where we rely on consent as the legal basis for processing (for example, for sending promotional emails or push notifications), you may withdraw that consent at any time by updating your communication preferences in your account settings or by contacting our support team.

5 Data Sharing & Third-Party Disclosure

l89l does not sell, rent, or otherwise transfer your personal data to unaffiliated third parties for their own marketing or commercial purposes. We share personal data only in the following limited circumstances:

5.1 Service Providers

We engage trusted third-party service providers who process data on our behalf and under our instruction, including KYC and identity verification providers, payment processing partners (bKash, Nagad, Rocket, Upay, Visa, Mastercard), cloud hosting and infrastructure providers, fraud detection and anti-money-laundering screening services, and customer support platform operators. All service providers are bound by contractual data processing agreements that restrict the use of your data to the specific service being delivered.

5.2 Game Studio Partners

When you play games provided by third-party studios such as Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, or Ezugi, a session token and anonymised player identifier may be shared with those studios to authenticate your game session and record outcomes. Full personal identity data is not transmitted to game studios.

5.3 Legal and Regulatory Disclosure

l89l may disclose personal data to law enforcement agencies, regulatory bodies, or other authorised public authorities where we are required to do so by applicable law, court order, or lawful government request. We will notify you of any such disclosure to the extent permitted by law.

6 Payment Data & Financial Information

l89l processes payment transactions in Bangladeshi Taka (৳ BDT) exclusively through certified payment partners. All payment card data (Visa, Mastercard) is handled directly by PCI-DSS-compliant payment processors; l89l does not store full card numbers, CVV codes, or card expiry dates on its own servers at any point.

For mobile financial service transactions via bKash, Nagad, Rocket, and Upay, l89l receives only the transaction confirmation reference, amount, and registered mobile number associated with the transaction. Full wallet credentials are never exposed to l89l systems.

Transaction records are retained for a minimum of five years from the date of the transaction to meet financial record-keeping obligations. These records may be made available to authorised regulatory or law enforcement bodies upon lawful request.

7 Cookies & Tracking Technologies

l89l uses cookies and similar tracking technologies to operate the platform correctly, maintain your authenticated session, and improve your experience. The categories of cookies we use are as follows:

7.1 Strictly Necessary Cookies

These cookies are essential for the platform to function. They maintain your login session, remember your language preference, and enable secure page navigation. They cannot be disabled without breaking the platform's core functionality.

7.2 Performance & Analytics Cookies

These cookies collect anonymised data about how players interact with the l89l platform — which pages are visited most, where errors occur, and how long sessions last. This data is used solely to improve platform performance and user experience.

7.3 Functional Cookies

Functional cookies remember your preferences such as your chosen game lobby view, notification settings, and responsible gaming tool configurations. Disabling these cookies may cause some personalisation features to reset between sessions.

You can manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will impair your ability to log in or use core platform features. l89l does not use third-party advertising cookies or behavioural retargeting cookies.

8 Data Retention

l89l retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following general retention periods apply:

• Active account data: Retained for the lifetime of your account plus a minimum of five years following account closure;
• KYC and identity documents: Retained for a minimum of five years from the date of verification or account closure, whichever is later;
• Transaction records: Retained for a minimum of five years from the date of the transaction;
• Support communications: Retained for up to three years from the date of the communication;
• Technical and usage logs: Retained for up to 12 months from the date of collection, after which they are anonymised or deleted;
• Marketing consent records: Retained until you withdraw consent or your account is closed, plus one year thereafter.

When the applicable retention period expires, personal data is securely deleted or anonymised so that it can no longer be linked to you as an individual.

9 Your Data Rights

As a data subject, you have a number of rights in relation to the personal data l89l holds about you. These rights are summarised below. To exercise any of these rights, please contact our support team at [email protected] with the subject line "Data Rights Request". We will respond to verified requests within 30 days.

10 Data Security

l89l implements a layered security architecture to protect the personal data of all Bangladesh players against unauthorised access, accidental loss, alteration, or disclosure. Our core security measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and our servers;
• AES-256 encryption for sensitive data fields stored in our databases, including identity document references and payment method records;
• Bcrypt password hashing — your password is never stored in plain text; only a salted hash is retained;
• Role-based access controls ensuring that l89l staff can only access personal data necessary for their specific role;
• Regular penetration testing and vulnerability assessments conducted by independent security specialists;
• Two-factor authentication (2FA) available for player accounts as an additional layer of login security.

Despite these measures, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights, l89l will notify affected players without undue delay and will take all reasonable steps to contain and remediate the incident.

11 Children & Minors

The l89l platform is strictly intended for adults aged 21 years and above. We do not knowingly collect, process, or store personal data belonging to individuals under the age of 21. Age verification is a mandatory step in our KYC onboarding process, and accounts where the player is found to be under 21 are closed immediately.

If you believe that a minor has submitted personal data to l89l, please contact our support team at [email protected] immediately. Upon verification, we will delete all associated data without delay and close the relevant account. Parents and guardians in Bangladesh are encouraged to use device-level parental controls to restrict access to online gambling platforms.

12 Third-Party Links & External Services

The l89l platform may contain references or links to third-party services such as game studios, payment providers, or informational resources. These third parties operate under their own privacy policies, which l89l does not control and is not responsible for. We encourage you to review the privacy policy of any third-party service before submitting personal data to them.

l89l's Privacy Policy applies exclusively to data processed by l89l in connection with the l89l platform. It does not extend to any third-party website or service that you access independently, even if you first navigated to that service via a link on the l89l platform.

13 Updates to This Privacy Policy

l89l reserves the right to update or amend this Privacy Policy at any time. When material changes are made, we will post the revised policy on this page with a new effective date and, where the changes are significant, notify registered players by email or via an in-platform notification.

We encourage you to review this Privacy Policy periodically to stay informed about how we handle your personal data. Your continued use of the l89l platform after the effective date of any revised policy constitutes your acceptance of the updated terms. If you do not agree with any change, you should discontinue use of the platform and may request account closure by contacting our support team.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the personal data l89l holds about you, please reach out to our dedicated support team using the details below. All privacy-related communications are handled in English and treated with strict confidentiality.

• Email: [email protected] (plain text — not a clickable link)
• Subject Line for Data Requests: "Data Rights Request" or "Privacy Enquiry"
• Live Chat: Available 24/7 via the chat widget on the l89l platform
• Response Target: Data rights requests — within 30 days of verified submission; general privacy queries — within 48 hours
• Support Hours: 24 hours a day, 7 days a week, Bangladesh Standard Time (BST, UTC+6)

l89l takes all privacy complaints seriously. If you are not satisfied with the response to a privacy concern after contacting our support team, you may seek further recourse through the relevant data protection authority or dispute resolution channel applicable in your jurisdiction.