Privacy Policy — l89s

1Introduction

This Privacy Policy ("Policy") describes how l89s ("we", "us", "our", "Platform") collects, uses, stores, protects, and discloses personal information obtained from individuals ("you", "User", "Member") who access or use the l89s website at https://l89s.pro and all associated services, games, and features. This Policy forms an integral part of our Terms and Conditions and should be read alongside them.

By accessing or using the l89s platform in any capacity — including registering an account, making a deposit, placing a bet, or simply browsing — you confirm that you have read and understood this Policy and consent to the collection and use of your personal data as described herein. If you do not agree to this Policy, please discontinue your use of the l89s platform immediately.

2Information We Collect

l89s collects personal information through several channels in the ordinary course of operating the platform. The categories of data we may collect include, but are not limited to, the following:

• Identity data: full name, date of birth, gender, nationality, and national identity card (NID) or passport details provided during account registration or KYC verification.
• Contact data: mobile phone number, email address, and residential address. For Bangladesh-based members this typically includes a Dhaka, Chittagong, or other Bangladeshi city address.
• Financial data: payment method details (bKash wallet number, Nagad account, Rocket account, bank account or card details), transaction histories, deposit and withdrawal records, and account balance information.
• Technical data: IP address, browser type and version, device type, operating system, time zone setting, location data (where permitted), pages visited, session duration, click-stream data, and referring URLs.
• Usage data: gaming activity including games played, bets placed, wagers won or lost, sports betting markets selected, bonus usage, session frequency, and responsible gaming tool usage.
• Communications data: records of any correspondence between you and l89s customer support, including chat logs, email threads, and support ticket histories.

3How We Use Your Information

l89s uses the personal information we collect strictly for the purposes set out below. We do not use your data for any purpose that is incompatible with the reason for which it was originally collected without first obtaining your explicit consent.

• Account management: to create, verify, maintain, and administer your l89s account, including processing registration, conducting KYC checks, and managing account settings and preferences.
• Transaction processing: to process deposits and withdrawals via bKash, Nagad, Rocket, bank transfer, and other supported payment methods, and to maintain accurate financial records.
• Legal and regulatory compliance: to comply with applicable anti-money laundering (AML), counter-terrorist financing (CTF), and responsible gaming obligations, including age verification and transaction monitoring.
• Service improvement: to analyse usage patterns, test new features, improve the platform's performance, and personalise your experience on l89s, including surfacing games and promotions relevant to your preferences.
• Marketing communications: to send you promotional offers, bonus notifications, seasonal promotions (such as Eid, Durga Puja, or Pohela Boishakh offers), and platform updates — but only where you have given explicit consent to receive such communications. You may opt out at any time by contacting [email protected].
• Fraud prevention and security: to detect, investigate, and prevent fraudulent activity, money laundering, collusion, account takeover, and any other prohibited conduct in order to protect the integrity of the platform and the safety of all members.

4Our Privacy Commitments

5Legal Basis for Processing

l89s processes your personal data only where a valid legal basis exists. The primary legal bases on which we rely are:

• Contractual necessity: processing that is necessary to provide the services you requested when you registered your account and agreed to our Terms and Conditions. This includes account setup, transaction processing, and customer support.
• Legal obligation: processing required to comply with applicable AML, CTF, KYC, and responsible gaming laws and regulations, including transaction monitoring, identity verification, and record-keeping.
• Legitimate interests: processing for fraud prevention, platform security, abuse detection, and general service improvement where our legitimate interests are not overridden by your rights and freedoms.
• Consent: processing for marketing and promotional communications, and for any other purpose not covered by the above bases, where you have given us your free, informed, and explicit consent. You may withdraw consent at any time.

6Sharing Your Information

l89s does not sell your personal data. We share your information only with the following categories of recipients, and only to the extent necessary for the purposes described in this Policy:

• Payment processors and financial service providers: to facilitate deposits and withdrawals via bKash, Nagad, Rocket, Dutch-Bangla Bank, City Bank, BRAC Bank, and other supported payment methods. These partners process your payment data strictly under their own privacy commitments and applicable financial regulations.
• Identity verification and KYC providers: third-party services that assist l89s in verifying the identity, age, and payment method ownership of members in accordance with our AML and responsible gaming obligations.
• Regulatory and law enforcement authorities: where l89s is required by applicable law, court order, or regulatory directive to disclose personal data to a competent authority. We will notify you of any such disclosure where permitted to do so by law.
• Technology and hosting providers: companies that provide the technical infrastructure, cloud hosting, data storage, and software services that underpin the l89s platform. All such providers are bound by strict data processing agreements that prohibit them from using your data for their own purposes.

7Cookies and Tracking Technologies

l89s uses cookies and similar tracking technologies to operate the platform, improve performance, and deliver a better user experience. A cookie is a small text file placed on your device when you visit our website. We use the following categories of cookies:

• Strictly necessary cookies: these are essential for the platform to function correctly. They enable core features such as user authentication, session management, and security verification. These cookies cannot be disabled without impairing the operation of the platform.
• Performance and analytics cookies: these help us understand how members interact with the platform by collecting anonymous statistical data about page visits, session lengths, and feature usage. This data is used solely to improve the platform.
• Functional cookies: these enable enhanced functionality such as remembering your language preferences, previously visited sections, and personalised display settings. Disabling these cookies may affect the quality of your experience.
• Session cookies vs persistent cookies: session cookies expire when you close your browser and are used to maintain your logged-in state during a visit. Persistent cookies remain on your device for a set period and are used for preference retention and analytics.

You can control and manage cookies through your browser settings. Please note that disabling strictly necessary cookies will affect the functionality of the l89s platform. For guidance on managing cookies in your specific browser, consult your browser's help documentation.

8Data Retention

l89s retains personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, regulatory, or reporting requirements. The specific retention periods applicable to different categories of data are as follows: account and identity data is retained for a minimum of 5 years following account closure; financial transaction records are retained for a minimum of 5 years from the date of the transaction; communications data (support tickets, chat logs) is retained for 2 years; and technical/usage data is retained for up to 13 months for analytics purposes.

When personal data is no longer required for any legitimate purpose and no legal retention obligation applies, l89s will securely delete or anonymise it so that it can no longer be associated with you as an identifiable individual. We do not retain data in identifiable form beyond the periods described above.

9Your Rights Over Your Data

As a registered member of the l89s platform, you have a number of rights in relation to the personal data we hold about you. You may exercise any of these rights at any time by contacting our support team at [email protected]. We will respond to all valid requests within 30 days of receipt.

• Right of access: you have the right to request a copy of the personal data l89s holds about you. We will provide this in a commonly used, machine-readable format where technically feasible.
• Right to rectification: if any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or complete it without undue delay.
• Right to erasure: you have the right to 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 it has been processed unlawfully — subject to our legal retention obligations.
• Right to restriction of processing: you may request that we restrict processing of your data in certain circumstances — for example, where you contest its accuracy, where processing is unlawful but you oppose erasure, or where we no longer need the data but you require it for a legal claim.
• Right to data portability: where processing is based on your consent or on a contract, and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit that data to another data controller.
• Right to withdraw consent: where l89s processes your data on the basis of your consent (such as for marketing communications), you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

To exercise any of the above rights, please contact us at [email protected] with the subject line "Data Rights Request" and a clear description of the right you wish to exercise. We may need to verify your identity before processing your request. We will not charge a fee for handling any data rights request unless the request is manifestly unfounded or excessive.

10Data Security

l89s takes the security of your personal data seriously and has implemented a comprehensive set of technical, organisational, and procedural safeguards designed to protect your data against accidental loss, unauthorised access, misuse, alteration, or disclosure. Our security measures include, but are not limited to: SSL/TLS encryption for all data in transit; encrypted storage of sensitive data at rest; role-based access controls ensuring that only authorised personnel can access personal data; regular security audits and vulnerability assessments; and strict vendor due diligence requirements for all third-party data processors.

Despite these measures, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect your personal data using commercially reasonable means, we cannot guarantee its absolute security. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay in accordance with applicable notification requirements.

11Children's Privacy

The l89s platform is strictly intended for adults aged 21 and above. We do not knowingly collect, solicit, or process personal data from any individual under the age of 21. If we become aware that personal data has been collected from a person under 21 without appropriate parental or guardian consent, we will take immediate steps to delete that data and close the associated account. If you believe that a person under 21 has registered on the l89s platform or provided us with personal data, please notify us immediately at [email protected] so that we can take appropriate action.

12Third-Party Links and Services

The l89s platform may, from time to time, contain references to or integrations with third-party services, game providers (such as Pragmatic Play, Evolution Gaming, Spribe, or Ezugi), and payment processors. These third parties have their own independent privacy policies, and l89s is not responsible for their privacy practices or content. We strongly encourage you to review the privacy policy of any third-party service before providing them with your personal information. The inclusion of a link to or integration with a third-party service on the l89s platform does not constitute endorsement by l89s of that party's privacy practices.

13Changes to This Privacy Policy

l89s reserves the right to update, revise, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform features. When we make material changes to this Policy, we will update the "Last Updated" date at the top of this page and, where reasonably practicable, notify registered members via their registered contact details or through a prominent notice on the platform prior to the changes taking effect.

Your continued use of the l89s platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated Policy. We therefore encourage you to review this page periodically to stay informed of how l89s is protecting your information. If you do not agree to any revised version of this Policy, please stop using the platform and contact [email protected] to request account closure.

14Contact Us About Privacy

If you have any questions, concerns, or requests relating to this Privacy Policy or our data processing practices, please contact our dedicated privacy support team. All privacy-related requests and enquiries will be handled with strict confidentiality and responded to within 30 days of receipt. Bangladesh Standard Time (BST, UTC+6) applies to all response timelines.