ll89 Privacy Policy — How We Collect, Use, and Protect Your Personal Data

1 Introduction

This Privacy Policy ("Policy") explains how ll89 ("ll89", "we", "us", "our") collects, uses, stores, and protects the personal data of individuals ("you", "the Player", "User") who access or use the website at https://ll89.io and any associated products, services, or applications (collectively, the "Platform").

ll89 is committed to handling your personal data responsibly and transparently. This Policy is written in plain, formal English so that you can clearly understand your rights and our obligations. By registering an account, making a deposit, placing a bet, or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy.

This Policy should be read alongside the ll89 Terms and Conditions and the Responsible Gaming Policy. In the event of any conflict between this Policy and the Terms and Conditions, the Terms and Conditions shall prevail unless the conflict relates specifically to a matter governed by applicable data protection law, in which case the relevant legal requirements shall take precedence.

2 Data We Collect

2.1 Registration and Account Data

When you create an ll89 account, we collect the personal information you provide during the registration process. This includes your full legal name, date of birth, email address, mobile phone number, and your chosen account password (stored in encrypted form). This data is required to establish and maintain your account and to verify that you meet the eligibility requirements set out in the ll89 Terms and Conditions, including the minimum age of 21.

2.2 Identity Verification Data

To comply with our Know Your Customer (KYC) obligations and to protect the integrity of the Platform, ll89 may request copies of government-issued identity documents — such as your National Identity Card (NID) or passport — as well as proof of your registered payment method. These documents are collected for the sole purpose of verifying your identity and age, and are stored securely in accordance with the data retention terms described in Section 8 of this Policy.

2.3 Financial and Transaction Data

ll89 records details of all financial transactions conducted on your account, including deposits, withdrawals, bets placed, winnings credited, and bonus activity. We collect the payment method identifiers associated with your account — for example, your registered bKash or Nagad mobile number, or the last four digits of your Visa or Mastercard — but we do not store full card numbers or full mobile banking PINs on our systems.

2.4 Usage and Behavioural Data

We automatically collect data about how you interact with the ll89 Platform. This includes your IP address, browser type and version, operating system, device type, session duration, pages visited, games played, bets placed, and click-path data. This data is collected via cookies and similar tracking technologies as described in Section 6 of this Policy, and is used to improve Platform performance, personalise your experience, and detect fraudulent or suspicious activity.

2.5 Communications Data

When you contact ll89 customer support — whether via live chat, email, or any other channel — we retain records of those communications, including the content of your messages and the date and time of each interaction. These records are kept to resolve disputes, improve service quality, and comply with our legal obligations.

3 How We Use Your Data

ll89 uses the personal data we collect for the following specific purposes:

• Account Management: To create, maintain, and administer your ll89 account, including processing your registration, verifying your identity, and managing your account settings and preferences.
• Transaction Processing: To process deposits and withdrawals via bKash, Nagad, Rocket, Upay, Visa, and Mastercard, and to maintain accurate records of all financial activity on your account.
• Legal and Regulatory Compliance: To fulfil our obligations under applicable anti-money laundering (AML) regulations, responsible gaming requirements, and any other legal obligations that apply to the operation of the ll89 Platform.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, account takeover attempts, bonus abuse, and other forms of misuse of the Platform.
• Customer Support: To respond to your queries, resolve complaints, and improve the quality and responsiveness of ll89 customer support services.
• Responsible Gaming: To monitor your gaming activity and identify patterns that may indicate problem gambling behaviour, in order to fulfil our responsible gaming obligations and act on any requests for self-exclusion, deposit limits, or cooling-off periods.
• Marketing Communications: Where you have provided explicit consent, to send you promotional offers, bonus notifications, and updates about new products and features on the ll89 Platform. You may withdraw this consent at any time as described in Section 9.
• Platform Improvement: To analyse aggregated, anonymised usage data to improve the design, functionality, and content of the ll89 Platform and to optimise the player experience.

ll89 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or establishing a new legal basis for the processing.

4 Legal Basis for Processing

ll89 processes your personal data on one or more of the following legal bases, depending on the specific purpose for which the data is being processed:

• Contractual Necessity: Processing that is necessary to perform the contract between you and ll89 — for example, processing your deposits and withdrawals, maintaining your account, and settling your bets.
• Legal Obligation: Processing required for ll89 to comply with applicable legal obligations — for example, retaining transaction records for AML compliance purposes, or conducting identity verification in response to a regulatory requirement.
• Legitimate Interests: Processing that is necessary for ll89's legitimate business interests — for example, fraud detection, platform security, and analytics — provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing that is based on your freely given, specific, and informed consent — for example, the sending of marketing communications or the use of non-essential cookies. Where consent is the legal basis, you have the right to withdraw it at any time without affecting the lawfulness of processing carried out before the withdrawal.

5 Sharing Your Data

5.1 Payment Service Providers

To process your deposits and withdrawals, ll89 shares the minimum necessary financial data with our payment service partners, including bKash, Nagad, Rocket, Upay, Visa, and Mastercard. These partners act as independent data controllers in respect of the data they handle to process your transactions, and their processing is governed by their own privacy policies.

5.2 Identity Verification Partners

ll89 may engage third-party KYC and identity verification service providers to assist with the verification of identity documents and age confirmation. Any data shared with such providers is strictly limited to what is necessary for the verification process and is subject to contractual data protection obligations.

5.3 Technology and Platform Partners

The ll89 Platform is powered in part by third-party technology providers, including game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi. These providers may receive limited technical data — such as session tokens or game round identifiers — to deliver their services. They do not receive your full personal profile unless this is strictly necessary for the delivery of the game service.

5.4 Legal and Regulatory Disclosure

ll89 may disclose your personal data to law enforcement authorities, regulatory bodies, or other competent authorities if required to do so by applicable law, court order, or where we reasonably believe that disclosure is necessary to protect the rights, property, or safety of ll89, its players, or the public.

5.5 No Sale of Data

ll89 does not sell, rent, lease, or otherwise transfer your personal data to any unaffiliated third party for their own marketing or commercial purposes under any circumstances.

6 Cookies and Tracking Technologies

6.1 What Are Cookies

Cookies are small text files that are placed on your device by websites you visit. ll89 uses cookies and similar technologies — including web beacons, pixel tags, and local storage — to operate the Platform, remember your preferences, analyse usage patterns, and deliver a consistent and personalised experience.

6.2 Types of Cookies We Use

• Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly. They enable core features such as maintaining your login session, processing transactions, and applying security measures. These cookies cannot be disabled without significantly impairing Platform functionality.
• Analytical Cookies: These cookies collect anonymised information about how players use the Platform — for example, which pages are visited most frequently, how long sessions last, and where players navigate from. This data helps ll89 improve the Platform experience. These cookies are only activated with your consent.
• Functional Cookies: These cookies remember your preferences and settings — such as your preferred language or game display settings — so you do not need to reconfigure them on each visit.
• Marketing Cookies: Where you have consented, these cookies track your activity across the Platform to enable ll89 to deliver relevant promotional content. They do not track your activity across third-party websites.

6.3 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies at any time. Please note that disabling strictly necessary cookies may prevent you from accessing certain features of the ll89 Platform, including your account login.

7 Data Security

ll89 implements a comprehensive range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the ll89 Platform.
• Encrypted storage for sensitive account credentials, including passwords (which are stored as salted cryptographic hashes and never in plain text).
• Access controls that restrict access to personal data to ll89 staff and authorised service providers on a strictly need-to-know basis.
• Regular security audits and vulnerability assessments of the Platform infrastructure.
• Fraud monitoring systems that continuously analyse account activity for signs of unauthorised access or suspicious behaviour.

While ll89 takes all reasonable steps to protect your personal data, no data transmission over the internet or data storage system is completely immune to security risks. You are encouraged to use a strong, unique password for your ll89 account and to contact support immediately if you suspect that your account security has been compromised.

8 Data Retention

ll89 retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by applicable legal or regulatory obligations. The following retention principles apply:

• Active Account Data: Personal data associated with an active ll89 account is retained for the duration of your account's activity and for a minimum period following account closure, as required by AML record-keeping obligations.
• Transaction Records: Financial transaction records are retained for a minimum of five years following the date of the transaction, in accordance with standard AML regulatory requirements.
• Identity Verification Documents: Copies of identity documents submitted for KYC purposes are retained for the period required by applicable regulations, and are securely deleted thereafter.
• Support Communications: Records of customer support interactions are retained for a period sufficient to resolve any related disputes and to comply with our quality assurance obligations.
• Marketing Data: Where consent has been withdrawn, marketing preference data is updated promptly and you will no longer receive promotional communications. Historical records of consent and withdrawal are retained for audit purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that ensures it can no longer be associated with any identifiable individual.

9 Your Rights

As a player using the ll89 Platform, you hold the following rights in respect of your personal data. To exercise any of these rights, please contact the ll89 support team using the details provided in Section 13 of this Policy.

• Right of Access: You have the right to request a copy of the personal data that ll89 holds about you. ll89 will respond to verified access requests within a reasonable timeframe.
• Right to Rectification: If any personal data held by ll89 is inaccurate or incomplete, you have the right to request that it be corrected or updated.
• Right to Erasure: In certain circumstances, you have the right to request that ll89 delete your personal data. This right is subject to any overriding legal obligations that require us to retain specific data — for example, AML transaction records.
• Right to Restriction of Processing: You have the right to request that ll89 restrict the processing of your personal data in certain circumstances, for example while the accuracy of your data is being disputed.
• Right to Object: Where ll89 processes your personal data on the basis of legitimate interests, you have the right to object to that processing. ll89 will cease the processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where ll89 processes your data on the basis of your consent — for example, for marketing communications — you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing conducted prior to the withdrawal.
• Right to Data Portability: Where technically feasible and legally applicable, you have the right to receive a copy of your personal data in a structured, commonly used, machine-readable format.

10 Children's Privacy

The ll89 Platform is strictly for adults aged 21 and above. ll89 does not knowingly collect personal data from any individual under the age of 21. If ll89 becomes aware that personal data has been collected from a person under the minimum age, that data will be deleted immediately and the associated account will be closed. If you believe that a minor has registered an account on the ll89 Platform, please contact our support team immediately at [email protected] so that we can investigate and act accordingly.

11 Third-Party Links

The ll89 Platform may contain references to third-party services — such as game providers and payment processors — whose own privacy practices are governed by their respective privacy policies. ll89 is not responsible for the privacy practices, content, or data handling of any third-party service, and this Privacy Policy applies solely to the ll89 Platform and the data ll89 directly collects and processes. We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of ll89.

12 Changes to This Privacy Policy

ll89 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or Platform features. Where changes are material — for example, a change to how we use or share your personal data — ll89 will provide reasonable notice to registered players via the Platform or by email to your registered address prior to the change taking effect.

Non-material updates — such as corrections of typographical errors or minor clarifications — may take effect immediately upon publication. The effective date at the top of this Policy will be updated to reflect the date of the most recent revision. Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. We recommend reviewing this Policy periodically to stay informed of any changes.

13 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to ll89's handling of your personal data, please contact our support team using the following details:

• Email: [email protected]
• Live Chat: Available 24 hours a day, 7 days a week via the Platform
• Response Time: Data rights requests acknowledged within 5 business days; substantive responses within 14 business days
• Coverage: Serving players across all districts of Bangladesh, including Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, and Mymensingh