Your Privacy Matters
at l89w

1 Introduction

l89w operates as Bangladesh's leading online casino and sports betting platform. In the course of delivering our services to players across Dhaka, Chittagong, Sylhet, and the rest of Bangladesh, we collect and process certain categories of personal data. This Privacy Policy has been written to be clear, honest, and comprehensive so that every l89w player understands exactly how their information is handled.

By accessing or using the l89w platform, by registering an account, or by making a deposit via bKash, Nagad, Rocket, Upay, Visa, or Mastercard, you acknowledge that you have read and accepted the terms of this Privacy Policy. This Policy forms part of the wider legal framework governing your use of l89w, alongside our Terms & Conditions and Responsible Gaming policy.

If you have any questions or concerns about how your data is handled, you may contact our support team at any time by writing to [email protected]. All data-related queries are handled by our dedicated data protection team and will be acknowledged within 48 hours.

2 Data We Collect

l89w collects only the data that is necessary for the lawful and effective delivery of our platform services. The categories of personal data we collect are described in the table below.

l89w does not collect sensitive special-category data such as racial or ethnic origin, religious beliefs, political opinions, biometric data, or health information, unless such data is voluntarily provided in the context of a responsible gaming self-assessment or a support interaction directly related to player welfare.

3 How We Collect Data

l89w collects your personal data through several distinct channels depending on how you interact with the platform:

• Direct submission: Data you actively provide when registering an account, completing identity verification, making a deposit, requesting a withdrawal, contacting support, or updating your account settings.
• Automated technical collection: Data collected automatically as you navigate the l89w platform, including IP address, device identifiers, browser settings, page views, click paths, and session timing data via cookies and similar technologies.
• Payment provider data: Transaction reference data shared by payment processors such as bKash, Nagad, Rocket, Upay, Visa, and Mastercard when you initiate a deposit or withdrawal. l89w does not receive or store full card numbers or mobile banking PINs.
• Identity verification partners: During the KYC process, l89w may receive confirmation data from third-party identity verification service providers. These partners confirm document authenticity and cross-reference submitted identity details.
• Communications: Any personal information you include in emails, support tickets, or other correspondence with the l89w team is collected and stored as part of your account record.

l89w does not purchase personal data from third-party data brokers or list providers. All personal data held by l89w has been provided directly by the data subject or collected through authorised technical means in the course of providing platform services.

4 Purpose of Processing

The specific purposes for which l89w processes your personal data are as follows:

• Account management: To create, maintain, and administer your l89w account, including processing your registration, managing your profile, and handling account closure requests.
• Identity verification (KYC): To verify that you are a real person aged 21 or above, to confirm the accuracy of the information you have provided, and to satisfy our internal anti-fraud and compliance obligations.
• Payment processing: To facilitate deposits via bKash, Nagad, Rocket, Upay, Visa, and Mastercard, and to process withdrawal requests to your registered payment method.
• Platform delivery: To provide access to all games, betting markets, and features available on l89w, including cricket betting on BPL, IPL, T20 World Cup and ICC events, slots, and live casino games.
• Security and fraud prevention: To monitor account activity for signs of fraud, money laundering, bot usage, multi-accounting, and other forms of abuse that violate our Terms & Conditions.
• Responsible gaming: To monitor gambling behaviour patterns, enforce player-set limits, identify potential problem gambling indicators, and apply appropriate interventions in accordance with our Responsible Gaming policy.
• Customer support: To respond to your queries, investigate complaints, and maintain a record of all support interactions for quality assurance and dispute resolution purposes.
• Legal compliance: To meet applicable legal, regulatory, and reporting obligations, including the retention of financial transaction records and identity verification documents.
• Marketing (with consent): To send you promotional offers, bonus notifications, and platform news via email, where you have given your explicit consent to receive such communications and have not subsequently withdrawn that consent.

5 Sharing Your Data

l89w does not sell, rent, or trade your personal data to any third party for commercial marketing purposes. This is an absolute commitment. Your data may, however, be shared in limited and specific circumstances with trusted partners who are bound by strict confidentiality and data protection obligations:

• Payment processors: bKash, Nagad, Rocket, Upay, Visa, and Mastercard receive the minimum transaction data necessary to process your deposits and withdrawals. These providers operate under their own regulatory frameworks and privacy obligations.
• Identity verification providers: Third-party KYC service providers receive the identity documents and personal details you submit during verification to confirm their authenticity and validity.
• Game content providers: Providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi may receive your player session identifier for the purpose of delivering their games and maintaining game integrity. They do not receive your full identity, payment, or contact data.
• Law enforcement and regulatory authorities: l89w will disclose personal data to law enforcement agencies, courts, or government authorities where required by applicable law, where compelled by a valid legal order, or where l89w believes disclosure is necessary to prevent serious harm or criminal activity.
• Internal group companies: Where l89w operates through affiliated entities, data may be shared within the group on a need-to-know basis for the purposes of platform operations, compliance, and fraud prevention. All group entities are bound by this Privacy Policy.

All third-party data processors engaged by l89w are subject to formal data processing agreements that require them to process personal data only for the specified purpose, to maintain appropriate security standards, and not to retain data beyond the period necessary to complete the relevant processing task.

6 Data Retention

l89w retains personal data for no longer than is necessary to fulfil the purposes for which it was collected, taking into account applicable legal and compliance retention requirements. The general retention periods applied by l89w are as follows:

Upon expiry of the applicable retention period, l89w will securely delete or anonymise your personal data in accordance with industry-standard data destruction procedures. Anonymised data — from which it is no longer possible to identify you as an individual — may be retained indefinitely for aggregated analytics and platform improvement purposes.

7 Data Security

l89w implements a layered security framework to protect your personal data at rest and in transit. The technical and organisational security measures in place include:

• SSL/TLS encryption on all data transmission pathways between the player's device and l89w servers.
• Passwords stored using industry-standard one-way cryptographic hashing — l89w staff cannot view your plain-text password at any time.
• Access controls that restrict employee access to personal data on a strict need-to-know basis, enforced through role-based permissions and regular access audits.
• Continuous security monitoring with automated alerts for anomalous account activity, login attempts from unrecognised devices, and high-value transaction patterns.
• Regular internal security reviews and vulnerability assessments to identify and remediate potential weaknesses in the platform's security posture.
• Secure physical and cloud infrastructure with firewalled server environments and encrypted database storage.

Despite these measures, no data transmission over the internet or method of data storage can be guaranteed to be 100% secure. l89w takes all reasonable precautions to protect your data but cannot provide an absolute guarantee against all possible security threats. In the event of a data breach that is likely to result in a risk to your rights and freedoms, l89w will notify affected players promptly and in accordance with applicable legal obligations.

You also play an important role in keeping your data secure. You must keep your l89w password confidential, use a strong and unique password, and notify l89w immediately at [email protected] if you suspect that your account has been accessed without your authorisation.

8 Cookies & Tracking Technologies

l89w uses cookies and similar technologies to improve the functionality, performance, and security of the platform, and to understand how players interact with our services. A cookie is a small text file placed on your device when you visit the l89w website. Cookies do not contain your personal information in plain text and cannot execute code or deliver viruses.

The types of cookies used on the l89w platform include:

• Strictly necessary cookies: These are essential to the operation of the platform. They enable core functions such as login session management, security token validation, and payment flow continuity. You cannot opt out of strictly necessary cookies while using the platform.
• Performance cookies: These collect anonymised data about how visitors use the l89w platform — such as which pages are visited most frequently and whether error messages are encountered — to help us improve the platform experience over time.
• Functionality cookies: These remember your preferences — such as your preferred language, responsible gaming settings, and display configurations — so that the platform behaves consistently across your sessions.
• Analytics cookies: l89w may use third-party analytics tools to understand aggregate platform usage patterns. These cookies collect data in anonymised or pseudonymised form and are not used to identify individual players.

You may manage your cookie preferences through your browser settings. Most browsers allow you to block or delete cookies. Please note that disabling certain categories of cookies may affect the functionality of the l89w platform, including your ability to remain logged in or to access certain features.

9 Your Rights

As a player on the l89w platform, you hold meaningful rights in relation to your personal data. l89w is committed to honouring these rights promptly and transparently. Your rights include:

• Right of access: You may request a copy of all personal data that l89w holds about you. We will provide this in a clear, structured format within 30 days of your verified request.
• Right to rectification: If any personal data held about you is inaccurate or incomplete, you have the right to request that it be corrected. You may update basic account details directly through your account dashboard; more complex corrections may require written verification.
• Right to erasure: You may request that l89w delete your personal data. This right is subject to overriding legal obligations — for example, l89w is required to retain certain financial and KYC records for the periods stated in Section 6. Where erasure is not possible in full, l89w will inform you of the specific data categories that must be retained and the reason.
• Right to restrict processing: You may request that l89w pause the processing of your personal data in certain circumstances — for example, while the accuracy of data you have contested is being verified.
• Right to data portability: You may request that l89w provide your personal data in a structured, commonly used, machine-readable format for transfer to another service provider where technically feasible.
• Right to object: You may object to the processing of your personal data for direct marketing purposes at any time. Upon receipt of a valid objection, l89w will cease processing your data for that purpose without delay.
• Right to withdraw consent: Where l89w processes your data on the basis of your consent (for example, for marketing communications), you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of the above rights, please submit a written request to [email protected] with the subject line "Data Rights Request". Include your registered account username and a description of the right you wish to exercise. l89w will acknowledge your request within 48 hours and respond fully within 30 days. In cases of particular complexity, this period may be extended by a further 30 days, and you will be notified of the extension.

10 Minors & Age Policy

l89w takes its obligation to prevent underage gambling seriously. As part of our registration and KYC process, we require all new players to confirm their age and to provide government-issued identity documentation that verifies their date of birth. Where a discrepancy is identified or where l89w has reason to believe that a registered account belongs to a person under the age of 21, the account will be suspended immediately pending full identity verification.

If you are a parent or guardian and believe that a person under the age of 21 in your household has registered on the l89w platform or has accessed l89w games, please contact us immediately at [email protected]. l89w will investigate the matter promptly, suspend the relevant account, and return any funds deposited from a verifiably legitimate payment source. l89w recommends that parents and guardians use device-level parental controls and account supervision tools to prevent underage access to online gambling platforms.

Any personal data that l89w discovers to have been collected from a person under the age of 21 will be deleted immediately from our systems, subject only to any legal obligation to retain specific records related to the underage access incident itself.

11 International Data Transfers

l89w operates infrastructure and engages service providers that may be located outside of Bangladesh. As a result, your personal data may be transferred to and processed in countries other than your country of residence. l89w takes steps to ensure that any international transfer of personal data is conducted with appropriate safeguards in place to maintain the level of data protection described in this Privacy Policy.

These safeguards may include contractual data protection clauses agreed with third-party processors, the selection of processors operating in jurisdictions with adequate data protection frameworks, and technical security measures applied consistently across all data processing locations regardless of geography.

By using the l89w platform, you acknowledge that your personal data may be transferred internationally as described in this section. If you have concerns about specific data transfer arrangements, please contact us at [email protected] and we will respond with relevant information about the safeguards in place.

12 Third-Party Services

The l89w platform integrates with third-party services to deliver games, process payments, and verify player identities. These third-party services operate under their own privacy policies and terms of use. l89w is not responsible for the data practices of third-party providers beyond the scope of the data processing agreements in place between l89w and those providers.

Third-party game studios whose products are available on the l89w platform — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi — may collect certain technical data (such as game session identifiers and RNG audit logs) in the course of delivering their games. This data collection is limited to what is necessary for game delivery and integrity verification and does not include your full identity or financial details.

l89w does not endorse and is not responsible for the content, privacy practices, or security of any third-party website that may be referenced in any communication from l89w. Players are encouraged to review the privacy policy of any third-party service they interact with independently of the l89w platform.

13 Marketing Communications

l89w may send you promotional emails, bonus notifications, and platform news where you have given your explicit consent to receive such communications during registration or through your account settings. Marketing communications from l89w are always sent in English and relate exclusively to l89w's own products and services — we do not send marketing on behalf of third parties.

• You may withdraw your consent to receive marketing communications at any time by clicking the unsubscribe link in any marketing email or by updating your communication preferences in your account settings.
• Withdrawal of marketing consent will not affect your access to the l89w platform or the processing of your data for non-marketing purposes such as account management, KYC, and payment processing.
• l89w will process your withdrawal of consent promptly. You may continue to receive transactional emails — such as deposit confirmations, withdrawal notifications, and important account security alerts — regardless of your marketing communication preferences, as these communications are necessary to administer your account.
• l89w does not use SMS or phone calls for marketing purposes. Any unsolicited contact claiming to be from l89w via phone or SMS should be treated as suspicious and reported to [email protected] immediately.

14 Policy Changes

l89w reserves the right to update or revise this Privacy Policy at any time. Material changes to this Privacy Policy — meaning changes that significantly affect how we collect, use, or share your personal data — will be communicated to registered players via email to the address on file at least 7 days before the changes take effect.

The most current version of this Privacy Policy will always be available on the l89w platform at l89w.io/privacy-policy. The "Last Updated" date at the top of this document and in the table of contents sidebar reflects the date on which the most recent revision was made. We encourage you to review this Privacy Policy periodically to stay informed about how l89w protects your personal information.

Your continued use of the l89w platform after any updated Privacy Policy has taken effect constitutes your acceptance of the revised terms. If you do not agree with any changes made to this Privacy Policy, you should cease using the l89w platform and may request account closure by contacting [email protected].

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the handling of your personal data by l89w, please contact our data protection team using the details below. We are committed to resolving all privacy-related queries promptly and transparently.

Our support team operates 24 hours a day, 7 days a week on Bangladesh Standard Time (BST, UTC+6). We serve players across Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, and Cox's Bazar. All privacy communications are handled in English.

l89w takes data privacy seriously. We view the responsible handling of your personal information as fundamental to the trust that players place in our platform, and we are committed to maintaining the highest practicable standard of data protection across all our operations.