l89a Privacy Policy

1. Introduction

This Privacy Policy describes how l89a ("we", "us", "our") collects, processes, stores, and protects personal data provided by users ("you", "your") of the l89a platform at https://l89a.io, including all associated sub-pages and services. l89a is Bangladesh's premier online casino and sports betting platform, and we take our data protection obligations seriously.

This policy applies to all personal data we collect through your use of the platform, whether you are a registered player, a visitor browsing the site, or a person who contacts our support team. It covers data collected online, via mobile, and through any other channel associated with the l89a service.

By registering an account or continuing to use the l89a platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree to this policy, please discontinue use of the platform immediately.

2. Data Controller

l89a acts as the data controller in respect of the personal data collected through this platform. As data controller, l89a determines the purposes for which and the manner in which personal data is processed. All data-related enquiries, access requests, correction requests, and deletion requests should be directed to our dedicated privacy contact at:

• Email: [email protected]
• Subject Line: "Privacy Request — [Your Registered Username]"
• Response Time: Within 5 business days of receipt

Where l89a engages third-party processors (such as payment service providers or game software suppliers), those parties process data strictly on l89a's instructions and under binding data processing agreements. They do not act as independent data controllers in respect of your l89a account data.

3. Personal Data We Collect

3.1 Account Registration Data

When you create an l89a account, we collect the following information:

• Full legal name
• Date of birth (to verify you are 21 years of age or older)
• Residential address (including division, district, and postal code)
• Mobile telephone number (used for OTP verification and account security)
• Email address (if provided)
• Username and encrypted password

3.2 Identity Verification (KYC) Data

To comply with our anti-money-laundering and know-your-customer obligations, we may collect:

• National Identity Card (NID) number and a scan or photograph of the document
• Passport or driver's licence details
• Proof of address documents (utility bills, bank statements dated within three months)
• Selfie or live photograph for biometric verification purposes
• Ownership confirmation for bKash, Nagad, Rocket, or Upay accounts used for deposits

3.3 Financial Transaction Data

Every deposit, withdrawal, and account balance adjustment is recorded, including:

• Transaction amounts in BDT
• Payment method reference numbers (bKash transaction IDs, Nagad reference codes, bank transfer references)
• Transaction timestamps in Bangladesh Standard Time (UTC+6)
• Bonus credits, wagering activity, and promotional participation records

3.4 Technical & Usage Data

When you access the l89a platform, we automatically collect certain technical data, including:

• IP address and approximate geolocation (country and city level)
• Device type, operating system, and browser version
• Session timestamps and duration
• Pages visited, games played, and betting history
• Referral source (how you arrived at the l89a site)

3.5 Communications Data

If you contact l89a support by live chat, email, or any other channel, we retain records of that communication, including the content of messages, timestamps, and any attachments, for quality assurance and dispute resolution purposes.

4. How We Collect Your Data

l89a collects personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or respond to a survey or promotion.
• Automatically: Through cookies, web beacons, server logs, and similar tracking technologies as described in Section 8 of this policy.
• From third parties: From payment service providers (bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, and others) for transaction verification; from identity verification service providers for KYC purposes; and from fraud prevention databases where we have a legitimate interest in protecting the platform and its users.

5. How We Use Your Personal Data

l89a uses the personal data we collect for the following purposes:

Purpose	Data Used
Creating and managing your l89a account	Registration data, KYC data
Processing deposits, withdrawals, and account transactions	Financial transaction data, registration data
Verifying your identity and age (21+ compliance)	KYC data, registration data
Detecting and preventing fraud, money laundering, and bonus abuse	Technical data, financial data, KYC data
Providing customer support and resolving disputes	Communications data, account data
Delivering promotional offers and bonus notifications (where opted in)	Registration data, betting history
Improving platform performance and user experience	Technical and usage data
Complying with legal and regulatory obligations	All categories as required

l89a does not use your personal data for automated individual decision-making that produces significant legal effects without human review. Where automated tools assist in fraud detection or account risk scoring, a member of our compliance team reviews any consequential decisions before action is taken.

6. Legal Basis for Processing

l89a processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfil our obligations under the account agreement with you, including account management, payment processing, and KYC verification.
• Legal obligation: Processing required to comply with anti-money-laundering laws, age verification obligations, and any reporting requirements imposed by our licensing authority.
• Legitimate interests: Processing for fraud prevention, platform security, abuse detection, and service improvement, where those interests are not overridden by your rights and freedoms.
• Consent: Processing for direct marketing communications, personalised promotions, and non-essential cookies, where you have provided explicit opt-in consent. You may withdraw consent at any time by contacting [email protected].

7. Data Sharing & Disclosure

7.1 Service Providers

l89a shares personal data with carefully selected third-party service providers who assist in operating the platform. These include:

• Payment processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank, Visa, and Mastercard — for the sole purpose of processing your transactions.
• Game software providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and others — who may receive limited session data necessary to deliver game content.
• KYC and identity verification providers: Third-party platforms that assist in verifying the authenticity of identity documents submitted by players.
• IT infrastructure and cloud hosting providers: Who store and process platform data under strict data processing agreements with l89a.

All third-party processors are bound by contractual obligations prohibiting them from using your data for any purpose other than delivering their service to l89a, and from sharing your data with further parties without l89a's express written consent.

7.2 Legal & Regulatory Disclosure

l89a may disclose personal data to government authorities, law enforcement agencies, or regulatory bodies where required by applicable law, court order, or where disclosure is necessary to protect the rights, property, or safety of l89a, its players, or the public. We will notify affected players of such disclosures wherever legally permissible to do so.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of l89a's business, personal data held by l89a may be transferred to the acquiring entity as part of that transaction. Affected players will be notified prior to any such transfer, and the acquiring entity will be required to honour the commitments made in this Privacy Policy.

8. Cookies & Tracking Technologies

8.1 What Are Cookies?

Cookies are small text files placed on your device when you visit the l89a website. They enable the platform to remember your preferences, maintain your session, and collect usage analytics. l89a also uses web beacons (small transparent images) and local storage mechanisms for similar purposes.

8.2 Types of Cookies Used

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies that keep you logged in to your l89a account and security tokens. These cannot be disabled without breaking core functionality.
• Performance & Analytics Cookies: Used to understand how players interact with the platform — which pages are visited most, how long sessions last, and where errors occur. This data is used in aggregate form to improve the platform.
• Functional Cookies: Remember your preferences such as language selection, table game preferences, and display settings.
• Marketing Cookies: Used only where you have provided explicit consent, to serve relevant promotional content based on your platform activity and preferences.

8.3 Managing Cookies

You may manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may impair the functionality of the l89a platform, including the ability to maintain a logged-in session. For full instructions on managing cookies in your specific browser, refer to your browser's help documentation.

9. Data Security

l89a implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers.
• Encryption at rest for sensitive data stored on l89a's infrastructure, including KYC documents and financial records.
• Role-based access controls ensuring that l89a staff can only access personal data necessary for their specific role.
• Two-factor authentication (2FA) available on all player accounts via mobile OTP.
• Regular penetration testing and independent security audits of the l89a platform.
• Intrusion detection systems and 24/7 monitoring of platform infrastructure for anomalous activity.

Despite these measures, no online platform can guarantee absolute security. In the event of a data breach that poses a risk to your rights and freedoms, l89a will notify affected players without undue delay and will take all reasonable steps to mitigate the impact of the breach.

10. Data Retention

l89a retains personal data for the following periods, after which data is securely deleted or anonymised:

• Account registration data: Retained for the duration of your active account relationship with l89a, plus five years following account closure.
• KYC and identity verification documents: Retained for a minimum of five years following the end of the account relationship, as required by anti-money-laundering regulations.
• Financial transaction records: Retained for a minimum of five years following the date of the transaction.
• Customer support communications: Retained for three years from the date of the last communication in a given thread.
• Technical and usage data (logs): Retained for up to 12 months, after which they are anonymised and retained in aggregate form for platform analytics.
• Marketing consent records: Retained for as long as your consent remains active, plus three years following withdrawal of consent.

11. Your Data Rights

As a data subject, you hold the following rights in respect of your personal data held by l89a. To exercise any of these rights, submit a written request to [email protected] with the subject line "Data Rights Request":

• Right of Access: You may request a copy of all personal data l89a holds about you, along with information about how it is used.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data 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 l89a's legal retention obligations.
• Right to Restriction of Processing: You may request that l89a restrict the processing of your data in certain circumstances, such as while a dispute is being resolved.
• Right to Data Portability: You may request a machine-readable copy of the personal data you have provided to l89a, where processing is based on consent or contractual necessity.
• Right to Object: You may object to processing carried out on the basis of legitimate interests, including profiling for marketing purposes.
• 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.

l89a will respond to all valid data rights requests within five business days. In complex cases, we may extend this period by a further ten business days, in which case we will notify you of the extension and the reason for it.

12. Third-Party Links

The l89a platform may contain references to third-party payment providers, game software studios, and sports data services. This Privacy Policy applies solely to the l89a platform. l89a is not responsible for the privacy practices of any third-party service, and we encourage you to review the privacy policies of any third-party services you access in connection with your use of l89a.

13. Children & Minors

The l89a platform is strictly intended for adults aged 21 years and over. l89a does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21 years of age, we will delete that data immediately and permanently close the associated account. If you believe that a minor has registered an account on our platform, please notify us immediately at [email protected].

14. Amendments to This Policy

l89a reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will notify registered players by SMS to their confirmed mobile number, by email where an address is registered, and by displaying a prominent notice on the l89a platform. The revised policy will clearly display the new effective date at the top of the document. Your continued use of the platform after the effective date of a revised policy constitutes your acceptance of the updated terms. We recommend reviewing this page periodically to stay informed of how l89a protects your data.

15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by l89a, please contact our privacy team using the following details. All communications should be sent in English for the fastest response.

• Email: [email protected]
• Subject Line: "Privacy Enquiry" or "Data Rights Request"
• Live Chat: Available 24/7 via the live chat widget on the l89a platform
• Response Time: Within 5 business days for privacy-related requests
• Operating Hours: 24 hours a day, 7 days a week, Bangladesh Standard Time (UTC+6)