l89bd Privacy Policy — Your Data, Your Rights

01 Introduction and Scope

l89bd ("we", "us", "the Platform") is committed to protecting the privacy and personal data of every individual who accesses, registers on, or interacts with the l89bd website and its associated services. This Privacy Policy sets out, in clear and transparent terms, how we collect, process, store, share, and protect personal data in connection with the operation of the l89bd online casino and sports betting platform, which is designed specifically for players in Bangladesh.

This policy applies to:

• All registered account holders on the l89bd Platform
• Visitors who browse the l89bd website without registering
• Individuals who contact l89bd support via email or live chat
• Participants in any l89bd promotional campaign or tournament

This policy does not apply to third-party websites, payment processors, or game studios that may be linked from or integrated within the l89bd Platform. Those entities operate under their own privacy frameworks. We encourage you to review their policies independently.

02 Data Controller

For the purposes of this Privacy Policy, l89bd acts as the data controller in respect of personal data collected through the Platform. As data controller, l89bd determines the purposes and means of processing your personal data and is responsible for ensuring that processing activities comply with applicable data protection principles.

If you have any questions about how l89bd processes your personal data, or wish to exercise any of the rights described in Section 11, please contact our designated Data Protection contact using the details in Section 14.

03 Data We Collect

l89bd collects personal data through several channels. The categories of data we collect are described below, together with the context in which each category is gathered.

3.1 Registration and Account Data

• Full legal name (as it appears on your government-issued identity document)
• Date of birth (to verify you are 21 years of age or older)
• Residential address in Bangladesh (city, district, and postcode)
• Email address
• Mobile phone number (used for account verification and security alerts)
• Username and hashed password (passwords are never stored in plain text)
• Preferred language and currency settings

3.2 Identity Verification (KYC) Data

• Scanned or photographed copy of your National Identity Card (NID), passport, or driver's licence
• Proof of residential address (utility bill or bank statement not older than 3 months)
• Selfie or liveness check image (where required for enhanced KYC)
• Mobile banking account details (bKash, Nagad, Rocket, or Upay number) for payment verification

3.3 Financial Transaction Data

• Deposit and withdrawal history (amounts in BDT, timestamps, payment method used)
• Mobile banking transaction reference numbers
• Bank account or card details (stored in tokenised form — l89bd does not store raw card numbers)
• Bonus credit and wagering activity records

3.4 Gaming and Betting Activity Data

• Bet history (event, stake amount, odds, outcome, payout) for sports betting
• Game session logs (game title, session start/end, bet per round, win/loss) for casino games and slots
• Responsible gaming settings (deposit limits, session limits, self-exclusion status)

3.5 Technical and Device Data

• IP address and approximate geolocation (country and city level)
• Device type, operating system, and browser version
• Session timestamps and page interaction data (for fraud detection and platform improvement)
• Cookie identifiers (see Section 08 for full cookie policy)

3.6 Communication Data

• Email and live chat correspondence with l89bd support
• Responses to surveys or feedback forms
• Records of any formal complaints submitted

Data Category	Collection Point	Required / Optional
Registration Data	Account sign-up form	Required
KYC Documents	Verification centre (before first withdrawal)	Required for withdrawals
Financial Transaction Data	Deposit / withdrawal flows	Required
Gaming Activity Data	Platform automatically (during play)	Required (service delivery)
Technical / Device Data	Platform automatically (on access)	Required (security / fraud)
Communication Data	Support channels	Optional (user-initiated)
Marketing Preferences	Account settings / registration	Optional (consent-based)

04 How We Use Your Data

l89bd uses your personal data exclusively for the following purposes:

• Account Management: Creating, maintaining, and securing your l89bd account; enabling login and two-factor authentication; processing password resets and profile updates.
• Service Delivery: Processing bets and game sessions; calculating and crediting winnings; applying bonuses and promotional credits; providing customer support.
• Identity Verification and Fraud Prevention: Conducting KYC checks to verify your age and identity; screening against sanctions lists; detecting and preventing fraudulent activity, multi-accounting, and money laundering.
• Payment Processing: Facilitating deposits via bKash, Nagad, Rocket, Upay, and bank transfers; processing withdrawal requests; reconciling transaction records.
• Responsible Gaming: Monitoring gaming behaviour to identify signs of problem gambling; enforcing self-exclusion and deposit limit requests; sending responsible gaming reminders where appropriate.
• Legal Compliance: Maintaining records required by applicable financial regulations; responding to lawful requests from competent authorities; enforcing our Terms & Conditions.
• Platform Improvement: Analysing aggregated, anonymised usage patterns to improve game selection, interface design, and feature development. Individual user data is not used for commercial profiling.
• Marketing Communications: Sending promotional offers, bonus notifications, and event updates to users who have opted in to receive marketing communications. See Section 12 for opt-out instructions.
• Security Monitoring: Detecting unusual login activity, suspicious IP addresses, and potential account compromise to protect the integrity of your account.

05 Legal Basis for Processing

l89bd processes personal data on the following legal bases depending on the nature and purpose of the processing activity:

• Contractual Necessity: Processing required to perform our obligations under the User Agreement — including account registration, bet settlement, payment processing, and customer support — is carried out on the basis that it is necessary to fulfil the contract between l89bd and the User.
• Legal Obligation: Where l89bd is required to collect and retain data to comply with applicable financial regulation, anti-money-laundering requirements, or in response to lawful authority requests, processing is carried out on the basis of legal obligation.
• Legitimate Interests: Fraud detection, platform security monitoring, aggregated analytics, and responsible gaming oversight are carried out on the basis of l89bd's legitimate interests in operating a safe and fair platform. These activities are balanced against users' privacy interests and are limited to what is proportionate and necessary.
• Consent: Marketing communications and optional data collection activities (such as survey participation) are processed on the basis of your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

06 Data Sharing and Disclosure

l89bd does not sell, rent, or trade your personal data to any third party for commercial purposes. Data may be shared only in the following strictly defined circumstances:

6.1 Payment and Banking Partners

To process your deposits and withdrawals, l89bd shares the minimum necessary financial data with the relevant payment service providers, including bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, and card processing networks (Visa, Mastercard). These partners are contractually bound to process data solely for payment purposes and may not use it for any other objective.

6.2 KYC and Identity Verification Partners

To fulfil KYC obligations, l89bd may use third-party identity verification services. These partners process your identity documents and biometric data strictly for age and identity verification. All KYC partners are subject to strict data processing agreements.

6.3 Game Studios and Technology Providers

Game providers such as Evolution Gaming, Pragmatic Play, Microgaming, NetEnt, Ezugi, and Spribe receive session-level data (user identifier, bet amount, game outcome) to enable their games to function within the l89bd Platform. These providers do not receive your full personal profile.

6.4 Fraud Detection and Security Services

l89bd uses third-party fraud intelligence tools that may process IP addresses, device fingerprints, and behavioural data to identify and block fraudulent activity. This processing is based on l89bd's legitimate interests in platform security.

6.5 Legal and Regulatory Disclosure

l89bd may disclose personal data to law enforcement agencies, financial intelligence units, or courts where required to do so by applicable law or lawful order. l89bd will not voluntarily disclose user data to government bodies beyond what is legally required.

07 Data Retention

l89bd retains personal data only for as long as is necessary for the stated purpose or as required by applicable legal obligations. The following retention schedule applies:

Data Type	Retention Period	Basis
Account registration data	Duration of account + 5 years after closure	Legal / contractual obligation
KYC documents	Duration of account + 5 years after closure	Anti-money-laundering regulation
Financial transaction records	7 years from transaction date	Financial record-keeping requirement
Bet and game session history	Duration of account + 3 years after closure	Dispute resolution / legitimate interest
Support correspondence	3 years from last interaction	Legitimate interest / complaint resolution
Technical / device logs	12 months from generation	Security monitoring / fraud detection
Marketing preferences	Until consent is withdrawn or account is closed	Consent

When the applicable retention period expires, data is securely deleted or anonymised so that it can no longer be attributed to an individual. Anonymised, aggregated data (for example, platform usage statistics) may be retained indefinitely as it does not constitute personal data.

08 Cookies and Tracking Technologies

l89bd uses cookies and similar tracking technologies to operate the Platform, maintain your session, detect fraud, and — where you have consented — deliver relevant promotional content. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, anti-CSRF tokens, and load-balancing cookies. These cannot be disabled without impairing core functionality.
• Functional Cookies: Used to remember your preferences such as language settings, display options, and responsible gaming limits. Disabling these cookies may affect your personalised experience.
• Analytics Cookies: Used to collect aggregated, anonymised data about how users navigate the Platform. This helps l89bd identify usability issues and improve the interface. Analytics data is never linked to individual user profiles.
• Security Cookies: Used to detect unusual activity, flag suspicious login attempts, and support our fraud-detection systems. These cookies process IP addresses and device fingerprints.
• Marketing Cookies: Placed only with your explicit consent. Used to track whether you have interacted with a promotional campaign so that relevant offers can be attributed correctly. You may withdraw consent at any time via your account settings.

Most web browsers allow you to manage cookie preferences through their settings menu. You may block or delete cookies at any time; however, blocking strictly necessary cookies will prevent you from using core features of the l89bd Platform including logging in and placing bets.

09 Security Measures

l89bd employs a multi-layered security architecture to protect your personal data against unauthorised access, accidental loss, disclosure, or destruction. Our security programme includes the following technical and organisational measures:

• Transport Layer Security: All data in transit between your browser or app and l89bd servers is encrypted using TLS 1.3. We enforce HTTPS across all Platform endpoints and apply HTTP Strict Transport Security (HSTS) headers.
• Encryption at Rest: Sensitive data fields — including KYC documents, payment details, and identity information — are encrypted at rest using AES-256 encryption. Database-level encryption is enforced on all primary and backup storage systems.
• Password Security: User passwords are never stored in plain text. l89bd uses industry-standard one-way hashing algorithms with salting to ensure that passwords cannot be recovered even in the unlikely event of a data breach.
• Two-Factor Authentication (2FA): l89bd offers optional 2FA via one-time password (OTP) sent to your registered mobile number. We strongly recommend all users enable 2FA on their accounts.
• Access Controls: Access to personal data within l89bd's internal systems is restricted on a strict need-to-know basis. Staff with access to sensitive data are subject to background checks and regular data protection training.
• Intrusion Detection: l89bd's infrastructure is protected by real-time intrusion detection systems, Web Application Firewalls (WAF), and automated anomaly detection tools that monitor for suspicious access patterns 24 hours a day.
• Penetration Testing: The l89bd Platform undergoes regular third-party penetration testing and vulnerability assessments to identify and remediate security weaknesses before they can be exploited.
• Data Breach Response: In the event of a personal data breach that poses a risk to users, l89bd will assess the breach promptly and notify affected users without undue delay, providing details of the breach, the data affected, and the steps being taken to mitigate harm.

While l89bd takes all reasonable steps to protect your data, no online platform can guarantee absolute security. Users are strongly encouraged to use strong, unique passwords, enable 2FA, and notify l89bd immediately at [email protected] if they suspect unauthorised access to their account.

10 Children and Minors

The l89bd Platform is strictly intended for adults aged 21 years and above. l89bd does not knowingly collect, process, or retain personal data from any individual under the age of 21. Age verification is a mandatory step in the registration and KYC process.

If l89bd discovers or has reasonable grounds to believe that an account belongs to a person under 21 years of age, the account will be immediately suspended, all funds frozen pending investigation, and the account permanently closed. Any winnings generated during the period of underage use will be void and forfeited.

If you are a parent or guardian and believe that a minor has created an account on the l89bd Platform, please contact us immediately at [email protected]. We will investigate and close the account as a matter of urgency, returning any deposited funds that can be verified as belonging to the minor's parent or guardian after completing the necessary checks.

11 Exercising Your Rights

You may exercise any of the eight data subject rights listed in the summary section above by submitting a written request to l89bd's Data Protection contact. To protect the security of your account and the accuracy of our response, we may ask you to verify your identity before fulfilling a rights request.

The process for submitting a rights request is as follows:

1. Send an email to [email protected] with the subject line "Data Rights Request — [Your Username]"
2. State clearly which right you wish to exercise (e.g., access, erasure, portability)
3. Include any relevant details that will help us locate the correct data (e.g., date range of transactions, specific game sessions)
4. Attach a copy of your identity document to verify your identity (the same document used for KYC)
5. l89bd will acknowledge your request within 5 business days (BST, UTC+6)
6. l89bd will fulfil or respond substantively to your request within 30 calendar days of acknowledgement

In complex cases where a 30-day response is not feasible, l89bd will notify you within the initial 30-day period of the reason for delay and provide an extended timeline, not exceeding a further 60 days.

Please note that certain rights (in particular, the right to erasure) may be limited where l89bd is required to retain data to comply with a legal obligation, such as anti-money-laundering record-keeping requirements. Where a limitation applies, l89bd will explain the reason clearly in its response.

12 Marketing Communications

l89bd sends marketing communications — including bonus offers, tournament announcements, seasonal promotions (such as Eid, Pohela Boishakh, BPL season offers), and feature updates — only to users who have explicitly opted in to receive such communications at the point of registration or through their account settings.

Marketing communications are delivered primarily by email and, where consented, by SMS to your registered Bangladeshi mobile number. l89bd does not use push notifications for marketing without prior consent.

You may opt out of marketing communications at any time by:

• Clicking the "Unsubscribe" link at the bottom of any marketing email
• Updating your communication preferences in the "My Account" section of the Platform
• Sending an email to [email protected] with the subject line "Unsubscribe — [Your Username]"

Opting out of marketing communications will take effect within 5 business days. It will not affect transactional communications (such as deposit confirmations, withdrawal notifications, security alerts, or account verification messages), which are sent regardless of marketing preferences as they are necessary for the operation of your account.

13 Updates to This Privacy Policy

l89bd reviews and updates this Privacy Policy periodically to reflect changes in our data processing practices, regulatory requirements, or platform features. The version number and effective date at the top of this document indicate the current version in force.

When we make material changes to this policy — meaning changes that significantly affect how we collect or use your personal data — we will notify registered users by email to their registered address at least 14 days before the updated policy takes effect. The updated policy will also be published on the l89bd Platform with the revised effective date clearly displayed.

Continued use of the l89bd Platform after the effective date of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with a material change, you may close your account and request data deletion in accordance with Section 11 before the updated policy takes effect.

All previous versions of this Privacy Policy are superseded upon the publication of a new version. The applicable version is always the most recently published document available on the l89bd Platform.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way in which l89bd handles your personal data, please contact us using the following details. All contact information is provided as plain text only and is not a clickable link:

• Email: [email protected]
• Subject Line for Privacy Queries: Privacy Enquiry — [Your Username]
• Support Hours: 24 hours a day, 7 days a week (Bangladesh Standard Time, UTC+6)
• Response Time for Privacy Requests: Acknowledgement within 5 business days; full response within 30 calendar days

l89bd is committed to resolving all privacy-related queries and complaints promptly and transparently. If you are not satisfied with our response, you retain the right to seek independent advice or pursue any legally available avenue of recourse in your jurisdiction.