l89i Privacy Policy — How We Handle Your Personal Data

1 Who We Are

l89i is an international online betting and casino platform accessible at l89i.io, serving players across Bangladesh and other eligible regions. For the purposes of this Privacy Policy, l89i is the data controller responsible for the personal information collected through the platform, its associated mobile interfaces, and all related communications channels.

l89i is committed to operating as a safe and reliable online betting platform. All player data is handled in accordance with the principles outlined in this Policy and in line with applicable international data protection standards. We do not fabricate claims of regulatory approval from any specific Bangladeshi government body; however, we apply best-practice data governance frameworks across our operations.

If you have any questions about the identity of the data controller or wish to exercise any rights described in this Policy, please contact our Data Support team via the channels listed in Section 15.

2 Data We Collect

l89i collects personal data from you in the following categories, depending on how you interact with the platform:

3 How We Use Your Data

The personal data l89i collects is used for the following clearly defined purposes:

• Account Management: To create, maintain, and administer your l89i account, including verifying your identity, processing login requests, and managing your preferences.
• Transaction Processing: To facilitate deposits and withdrawals via bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, Visa, and Mastercard, and to maintain an accurate record of all financial activity on your account.
• Legal & Regulatory Compliance: To comply with anti-money laundering (AML) obligations, age verification requirements, and any other applicable legal duties, including responding to lawful requests from competent authorities.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, account takeover attempts, collusion, and other forms of Prohibited Activity as defined in our Terms & Conditions.
• Customer Support: To respond to your queries, resolve disputes, process complaints, and maintain a record of support interactions for quality assurance purposes.
• Platform Improvement: To analyse aggregated usage patterns, identify technical issues, and improve the design, performance, and content of the l89i platform.
• Responsible Gaming: To monitor account activity for indicators of problem gambling behaviour and to administer self-exclusion, deposit limit, and reality-check tools when requested by players.
• Marketing Communications: To send promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications. You may opt out at any time via your account settings.

4 Legal Basis for Processing

l89i processes your personal data on the following legal grounds, as applicable to each processing activity:

• Contractual Necessity: Processing required to fulfil the contract between you and l89i — including account creation, payment processing, and service delivery — is carried out on the basis that it is necessary to perform that contract.
• Legal Obligation: Processing required to comply with AML regulations, age verification laws, and lawful requests from regulatory or law enforcement authorities.
• Legitimate Interests: Processing carried out for fraud prevention, platform security, responsible gaming monitoring, and internal analytics, where these interests are not overridden by your privacy rights.
• Consent: Processing for direct marketing communications, non-essential cookies, and any other processing that requires your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5 Data Sharing & Disclosure

l89i does not sell, rent, or trade your personal data to any third party for commercial purposes. Your data may be shared only in the circumstances described below:

• Payment Processors: Transaction data is shared with payment service providers including bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, Visa, and Mastercard solely to process your financial transactions. These providers operate under their own privacy policies and are bound by contractual data protection obligations.
• Identity Verification Partners: Where KYC verification is required, identity documents and biographical data are shared with certified identity verification service providers. These partners are contractually required to process data only for the stated verification purpose.
• Game Content Providers: Gameplay data (game ID, wager amount, session token) may be shared with game studios including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Ezugi, and Spribe to enable game delivery and resolve disputes. Your full personal profile is not shared with game providers.
• Legal & Regulatory Authorities: l89i will disclose personal data to competent authorities where required by applicable law, valid court order, or regulatory obligation. We will notify you of such disclosure where legally permitted to do so.
• Fraud Prevention Agencies: Where fraud, money laundering, or other criminal activity is suspected, relevant data may be shared with fraud prevention organisations and law enforcement agencies.
• Business Transfers: In the event of a merger, acquisition, or sale of business assets, your personal data may be transferred as part of that transaction. You will be notified of any such transfer and any change in data controller identity.

6 Payment Data & AML

l89i takes the security of financial data with the utmost seriousness. The following specific protections apply to payment-related personal data:

• Full payment credentials — including bKash wallet PINs, Nagad PINs, full bank card numbers, and CVV codes — are never transmitted to or stored on l89i's own servers. All sensitive payment data is handled exclusively by certified payment gateways.
• l89i retains a reference record of the last four digits of a registered mobile wallet number or card solely to facilitate withdrawal routing and account matching. This partial reference cannot be used to initiate any transaction.
• All transactions are denominated in Bangladeshi Taka (BDT / ৳). l89i maintains a full audit trail of all deposits and withdrawals for a minimum of five years in compliance with AML best practices.
• Players may be required to submit source-of-funds documentation — such as bank statements, salary slips, or business income evidence — before a withdrawal exceeding internal threshold amounts is approved. This is a standard AML due-diligence measure.

7 Cookies & Tracking

l89i uses cookies and similar tracking technologies to operate the platform effectively, remember your preferences, and analyse usage patterns. The categories of cookies used are:

You may manage your cookie preferences via your browser settings at any time. Disabling strictly necessary cookies will impair the functionality of the l89i platform and may prevent you from accessing your account. Disabling analytics or marketing cookies will not affect platform access but may result in less relevant promotional communications.

8 Data Retention

l89i retains personal data only for as long as is necessary for 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 full duration of your account's existence plus a minimum post-closure period of five years to satisfy AML record-keeping obligations.
• Transaction Records: Retained for a minimum of five years from the date of each transaction, in line with standard financial record-keeping requirements.
• Identity Verification Documents: Retained for a minimum of five years following account closure or the date of the last transaction, whichever is later.
• Customer Support Records: Retained for three years from the date of the last support interaction, unless a longer period is required for dispute resolution purposes.
• Marketing Preference Data: Retained until you withdraw consent or for one year following account inactivity, whichever is sooner.
• Technical & Usage Logs: Retained in identifiable form for up to 13 months, after which they are either deleted or anonymised for aggregate analytics purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be attributed to any individual. Anonymised aggregate data may be retained indefinitely for statistical analysis and platform development purposes.

9 Data Security

l89i implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Key security measures include:

• TLS 1.3 / SSL encryption for all data in transit between your device and l89i's servers.
• Encryption at rest for sensitive data fields stored in l89i's database infrastructure.
• Role-based access controls ensuring that only authorised personnel with a specific operational need can access personal data.
• Multi-factor authentication requirements for all internal system access by l89i staff.
• Regular independent security audits and vulnerability assessments of the platform infrastructure.
• Automated real-time monitoring for suspicious access patterns, data exfiltration attempts, and account takeover signals.
• Documented incident response procedures ensuring rapid containment and notification in the event of a confirmed data breach.

10 Your Rights

As a data subject, you hold the following rights in relation to the personal data l89i holds about you. To exercise any of these rights, contact our support team using the details in Section 15. We will respond within 30 days of receiving a valid request.

• Right of Access: You may request a copy of all personal data l89i holds about you, along with information about how it is processed.
• Right to Rectification: You may request that inaccurate or incomplete personal data be corrected or updated without undue delay.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to l89i's legal retention obligations (including AML requirements, which may override erasure requests in certain circumstances).
• Right to Restriction: You may request that processing of your data be restricted in certain circumstances, for example while the accuracy of data is disputed.
• Right to Data Portability: You may request that data you have provided to l89i be transferred to you in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing carried out on the basis of legitimate interests, including profiling for direct marketing purposes. Marketing opt-outs take effect within 48 hours of a request being submitted.
• 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 before the withdrawal.

11 Children & Minors

l89i operates a strict 21+ age policy. The platform is not directed at, intended for, or designed to attract persons under the age of 21. l89i does not knowingly collect personal data from any individual under 21 years of age.

If we become aware that personal data has been collected from a person under 21 — whether through misrepresentation at registration or any other means — that account will be immediately suspended, all associated data will be reviewed, any real-money balance will be handled in accordance with our Terms & Conditions, and the data will be deleted to the extent permitted by applicable law.

If you are a parent or guardian and believe that a minor under your care may have registered an account on l89i, please contact our support team immediately at [email protected]. We will investigate and take appropriate action without delay.

12 International Transfers

As an international online platform, l89i may process and store personal data on servers located outside of Bangladesh. Where personal data is transferred internationally, l89i ensures that appropriate safeguards are in place to provide a level of data protection equivalent to that described in this Policy.

Safeguards for international data transfers include contractual data protection clauses with all data processors, technical security controls consistent with those described in Section 9, and regular review of third-party processor compliance with agreed data protection standards.

By using the l89i platform and providing your personal data, you acknowledge that your information may be transferred to and processed in countries outside Bangladesh as described in this section.

13 Third-Party Links

The l89i platform may contain references to third-party game providers and payment partners. While these relationships are integral to platform operation, l89i is not responsible for the privacy practices of third-party websites or services that are independent of the l89i platform.

Game content delivered by third-party studios including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Ezugi operates within the l89i platform environment. Data shared with these providers is limited to what is necessary for game delivery as described in Section 5. These providers maintain their own privacy standards, which l89i contractually requires to meet minimum data protection benchmarks.

l89i is not responsible for the content, security, or privacy practices of any website outside of l89i.io. We recommend reviewing the privacy policy of any third-party service you interact with independently of the l89i platform.

14 Policy Updates

l89i reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, applicable law, or platform functionality. The effective date at the top of this Policy will be updated with each revision.

Where changes are material — meaning they substantially affect how your data is used or your rights as a data subject — l89i will notify registered players via the email address associated with their account at least 14 days before the changes take effect. Non-material changes (such as formatting corrections or clarifications that do not alter the substance of the Policy) may be made without specific notification.

Your continued use of the l89i platform after the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not accept the revised Policy, you must cease using the platform and contact our support team to request account closure.

15 Contact & Complaints

If you have questions about this Privacy Policy, wish to exercise any of your data rights, or wish to raise a complaint about how l89i has handled your personal data, please contact our Data Support team through the following channels:

• Live Chat: Available 24/7 via your account dashboard. Average response time: 2–5 minutes. Select "Data & Privacy" as the support category when initiating your chat.
• Email: [email protected] — Please include "Privacy Request" in the subject line along with your registered account username. Average response time: 2–12 hours.

All privacy-related support is conducted in English. l89i aims to acknowledge formal data complaints within 24 hours and resolve them within 30 calendar days, in accordance with standard data protection response timescales (Bangladesh Standard Time, UTC+6).

If you are not satisfied with l89i's response to your privacy complaint, you have the right to escalate your complaint to the relevant data protection supervisory authority in your jurisdiction. l89i will cooperate fully with any such authority in the investigation and resolution of privacy complaints.