Privacy Policy — How l89p Protects Your Personal Data

Who We Are and How to Contact Us

l89p is an online casino and sports betting platform operated for players based in Bangladesh, accessible at l89p.io. For the purposes of this Privacy Policy, l89p acts as the data controller in respect of all personal data collected from registered account holders and visitors to the l89p website.

If you have any questions, concerns, or requests related to your personal data or to this Privacy Policy, you may contact us at any time using the details below:

All privacy-related correspondence should reference your registered account username or email address so that we can locate your data record promptly.

The Personal Data We Collect

l89p collects personal data from you in the following contexts: when you register an account, when you make or receive a payment, when you use the platform, when you contact customer support, and when you interact with responsible gaming tools. The categories of personal data we collect are described below.

2.1 Registration Data

When you create an l89p account, we collect:

• Your full legal name
• Your date of birth (used to verify you meet the 21+ age requirement)
• Your residential address in Bangladesh (city, district, postcode)
• Your email address
• Your chosen username

2.2 Identity Verification (KYC) Data

To comply with our Know Your Customer obligations and to prevent fraud and underage access, we collect:

• Copies of government-issued identity documents, such as your National Identity Card (NID) or passport
• Proof of residential address (utility bill, bank statement dated within 90 days)
• Selfie photographs taken alongside a government-issued photo ID, where requested
• Confirmation of ownership of the mobile wallet (bKash, Nagad, Rocket) used for deposits

2.3 Financial and Transaction Data

When you deposit or withdraw funds, we collect:

• Mobile wallet numbers (bKash, Nagad, Rocket, Upay) used for transactions
• Bank account details where bank transfer is used
• Transaction amounts, dates, and reference numbers
• Records of deposits, withdrawals, bonus claims, and wagering activity

2.4 Usage and Technical Data

When you use the l89p platform, we automatically collect certain technical information including:

• IP address and approximate geographic location
• Device type, operating system, and browser type
• Pages visited, games played, session duration, and navigation patterns within the platform
• Login timestamps and session logs

2.5 Communications Data

If you contact l89p customer support, we retain a record of:

• The content of your correspondence (email, live chat transcripts)
• The date and nature of your enquiry
• Any resolution steps taken

2.6 Responsible Gaming Data

If you use any of the responsible gaming tools available on the l89p platform — including deposit limits, session alerts, cooling-off periods, or self-exclusion — we record the settings you apply and the dates on which changes were made. This data is treated as sensitive and is handled with additional protections as described in Section 11.

How and Why We Use Your Personal Data

l89p uses the personal data it collects for the following clearly defined purposes. We do not use your data for any purpose that is incompatible with the purpose for which it was originally collected without obtaining your prior consent.

l89p does not use personal data for automated decision-making that produces legal or similarly significant effects without human review. Fraud-detection algorithms flag accounts for human investigation; they do not independently action account closures.

Legal Basis for Processing

For each purpose described in Section 3, l89p relies on one of the following legal bases for processing your personal data:

• Contractual necessity — processing required to perform the contract between you and l89p (i.e., to operate your account, process transactions, and provide access to games). This covers account management, KYC, payment processing, and customer support.
• Legitimate interests — processing that serves l89p's legitimate operational interests and is not overridden by your rights. This covers fraud prevention, platform security, usage analytics, and platform improvement activities.
• Legal obligation — processing required to comply with applicable laws and regulatory requirements, including anti-money-laundering obligations and cooperation with law enforcement where legally compelled.
• Consent — processing for marketing and promotional communications, which we only carry out where you have given clear, freely given consent. You may withdraw this consent at any time by contacting [email protected].

Sharing Your Personal Data with Third Parties

l89p does not sell, rent, or commercially disclose your personal data to third parties. Data is shared only in the following strictly controlled circumstances:

5.1 Payment Processors

To process deposits and withdrawals, l89p shares the minimum necessary financial data with mobile financial service providers (bKash, Nagad, Rocket, Upay) and banking partners (Dutch-Bangla Bank, BRAC Bank, City Bank, Islami Bank). These partners act as independent data controllers in respect of transaction data processed through their own systems and are bound by their own regulatory obligations.

5.2 KYC and Identity Verification Providers

Where third-party identity verification services are used to assist with document authentication and age verification, identity documents may be shared with those providers. All KYC partners are bound by strict confidentiality obligations and are prohibited from using the data for any purpose other than identity verification on behalf of l89p.

5.3 Game Software Providers

Game studios and software providers (such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi) may receive session and wagering data necessary to deliver their games and calculate RTP performance. This data is aggregated and does not include personally identifiable information such as your name, address, or payment details unless strictly required by the provider's platform architecture.

5.4 Law Enforcement and Regulatory Bodies

l89p will disclose personal data to law enforcement agencies, courts, or regulatory authorities where it is legally required to do so, or where disclosure is necessary to protect the rights, property, or safety of l89p, its players, or the public. In such cases, disclosure is limited to the data specifically requested and is documented internally.

5.5 Business Transfers

In the event of a merger, acquisition, or sale of all or part of l89p's business operations, personal data held by l89p may be transferred to the acquiring entity as part of the transaction. In such circumstances, we will notify registered account holders by email prior to any transfer of their personal data and will ensure that the acquiring entity is bound by privacy obligations no less protective than those set out in this policy.

Cookies and Tracking Technologies

The l89p platform uses cookies and similar tracking technologies to deliver and improve the service. Cookies are small text files placed on your device when you visit the l89p website. They allow the platform to recognise your device on subsequent visits and to maintain your session while you are logged in.

6.1 Essential Cookies

Essential cookies are strictly necessary for the l89p platform to function. They maintain your login session, remember your language preferences, and support security features. These cookies cannot be disabled without breaking the platform's core functionality.

6.2 Analytics Cookies

l89p uses analytics tools to collect aggregated, anonymised data about how users navigate the platform. This data helps us identify technical issues, improve page performance, and optimise the user experience. Analytics cookies do not identify you personally.

6.3 Functional Cookies

Functional cookies remember preferences such as your chosen game lobby view, recently played games, and notification settings. These cookies improve the consistency of your experience across sessions.

6.4 Managing Cookies

You can manage or disable cookies through your browser settings at any time. Please note that disabling essential cookies will impair your ability to log in and use the l89p platform. Instructions for managing cookies are available in the help documentation for all major browsers.

Data Security Measures

l89p applies a layered approach to data security. The following technical and organisational measures are in place to protect your personal data against unauthorised access, disclosure, alteration, or destruction:

• 256-bit SSL encryption on all data transmitted between your device and the l89p platform
• Encrypted storage for all personal data at rest, including identity documents and payment information
• Role-based access controls limiting access to personal data to authorised l89p personnel who require it for legitimate operational purposes
• Continuous intrusion detection and security monitoring across all platform infrastructure
• Regular penetration testing by independent security professionals to identify and remediate vulnerabilities
• Staff data-protection training for all personnel who handle personal data as part of their role
• Incident response procedures that require prompt notification to affected users in the event of a data breach that poses a risk to your rights

Data Retention Periods

l89p retains personal data for defined periods based on the purpose for which it was collected and applicable legal obligations. The table below summarises our standard retention schedule.

Once the applicable retention period expires, personal data is securely deleted or irreversibly anonymised so that it can no longer be associated with any individual account holder.

Your Rights as a Data Subject

As a registered l89p account holder, you hold the following rights with respect to the personal data we hold about you. To exercise any of these rights, contact [email protected] with the subject line "Data Subject Request — [Right Being Exercised]". l89p will respond within 30 days.

• Right of Access: You may request a copy of all personal data l89p holds about you, including the categories of data, the purposes of processing, and any third parties with whom it has been shared.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it promptly.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where you object to processing. This right is subject to legal retention obligations — certain transaction and KYC records must be retained regardless of an erasure request.
• Right to Restriction of Processing: You may request that we temporarily restrict how we use your data while a dispute or correction request is being resolved.
• Right to Data Portability: You may request that l89p provide your account registration and transaction data in a structured, machine-readable format so that it can be transferred to another service provider.
• Right to Object: You may object to the processing of your data where l89p relies on legitimate interests as its legal basis, or where data is processed for direct marketing purposes. Objection to marketing processing will be actioned immediately.
• Rights Related to Automated Decision-Making: You have the right not to be subject to a decision based solely on automated processing that produces significant legal effects. As noted in Section 3, l89p uses fraud detection algorithms only to flag accounts for human review, not to take autonomous action.

Children and Minors

The l89p platform is strictly intended for adults aged 21 years and above. l89p does not knowingly collect or process personal data from individuals under the age of 21. The KYC verification process is specifically designed to prevent minors from accessing real-money gambling services.

If l89p becomes aware that personal data has been collected from a person under 21, the relevant account will be immediately suspended and all associated personal data will be deleted, except where retention is required to comply with legal obligations related to the identification and prevention of underage gambling.

If you are a parent or guardian and believe a minor has registered an account on the l89p platform, please contact [email protected] immediately. We take underage access extremely seriously and will respond to all such reports within 24 hours.

Responsible Gaming and Sensitive Data

Data generated through the use of responsible gaming tools on the l89p platform — including self-exclusion requests, deposit limit settings, cooling-off period activations, and session time alerts — is classified as sensitive operational data and is subject to the following additional protections:

• Responsible gaming data is accessible only to personnel with a specific operational need, such as the responsible gaming compliance team and, where relevant, customer support staff handling a welfare enquiry.
• This data is never used for marketing, personalisation, or commercial profiling purposes.
• Self-exclusion records are retained for the full duration of the exclusion plus 5 years, to allow l89p to enforce any future re-registration attempts and to demonstrate compliance with responsible gaming obligations.
• Where a player's responsible gaming data indicates a potential gambling harm situation, l89p may use this data proactively to contact the player and offer support resources — this use is in the player's legitimate interest and overrides standard data-minimisation preferences.

For more information about the responsible gaming tools available at l89p, please visit our Responsible Gaming page.

Changes to This Privacy Policy

l89p reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data-handling practices, applicable law, or the services we provide. Where changes are material — meaning they affect the purposes for which we use your data, the categories of data we collect, or your rights as a data subject — registered account holders will be notified by email to their registered address at least 14 days before the changes take effect.

Minor clarifications and non-material updates may be made without prior notice. The effective date at the top of this document will always reflect when the current version came into force. We recommend bookmarking this page and reviewing it periodically. Continued use of the l89p platform following the effective date of any updated Privacy Policy constitutes acceptance of the revised terms.

Contact and Complaints

For all privacy-related enquiries, data subject requests, and complaints regarding how l89p handles your personal data, please contact our team using the details below. All enquiries are handled confidentially and responded to within 30 days.

If you are not satisfied with the response you receive from l89p's support team regarding a privacy complaint, you have the right to escalate the matter through the applicable legal channels in your jurisdiction. l89p will cooperate fully with any lawful regulatory investigation into its data-handling practices.