l89v Privacy Policy — How We Collect, Use, and Protect Your Personal Data

1 Introduction

This Privacy Policy ("Policy") is issued by l89v ("l89v", "we", "us", "our") and applies to all personal data collected from individuals ("you", "Player", "User") who access or use the l89v online casino and sports betting platform at https://l89v.io and all associated subdomains and mobile interfaces (the "Platform").

l89v is committed to protecting the privacy and security of your personal information. This Policy has been written to be clear, specific, and honest about our data practices. We encourage you to read it in full before registering an account or making your first deposit.

By accessing the Platform, creating an account, or using any of our services, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the Platform.

2 Data Controller

For the purposes of applicable data protection law, l89v acts as the data controller in respect of the personal data you provide when using the Platform. As data controller, l89v determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is lawful, fair, and transparent.

All data protection enquiries, subject access requests, and complaints should be directed to the l89v Privacy Team. Contact details are provided in Section 13 of this Policy. l89v will acknowledge all privacy-related correspondence within 5 business days (Bangladesh Standard Time, UTC+6).

3 Data We Collect

l89v collects the following categories of personal data from players. The specific data collected from any individual player depends on the features of the Platform they use and the stage of their account lifecycle.

3.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identity document
• Date of birth
• Residential address in Bangladesh (district, city, postal code)
• Mobile phone number registered in your name
• Email address (where provided during registration)
• Copies of government-issued identity documents (National Identity Card, passport, or driving licence) submitted for KYC verification

3.2 Financial Data

• Payment method identifiers, including bKash and Nagad account numbers associated with your registered mobile number
• Rocket and Upay wallet identifiers where applicable
• Bank account details where bank transfer is used for deposits or withdrawals
• Deposit amounts, withdrawal amounts, transaction timestamps, and transaction reference numbers
• Account balance history and bonus credit/debit records

3.3 Gaming and Behavioural Data

• Records of all bets placed, games played, and sports markets accessed
• Bet stakes, win/loss outcomes, and wagering turnover history
• Session start times, session durations, and session end times
• Game preferences and navigation patterns on the Platform
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)

3.4 Technical Data

• IP address and approximate geographic location derived from IP
• Device type, operating system, and browser type and version
• Unique device identifiers where your device permits their collection
• Pages viewed, links clicked, and time spent on each page of the Platform
• Error logs and diagnostic data generated during your Platform sessions

3.5 Communications Data

• Content of live chat conversations with l89v support agents
• Content of email correspondence sent to or received from l89v
• Records of any SMS or push notifications sent to you and your interaction with them
• Feedback and survey responses you voluntarily submit

4 How We Collect Data

l89v collects personal data through the following means:

• Direct provision by you: Data you enter during account registration, KYC verification, deposit and withdrawal requests, contact form submissions, and live chat sessions.
• Automated technologies: Data collected automatically when you access the Platform, including IP addresses, device identifiers, session logs, and cookie data.
• Third-party KYC providers: Where you submit identity documents, our KYC verification partners may return additional verification data such as document authenticity scores and facial match confidence scores, which are recorded on your account file.
• Payment processors: Transaction confirmation data, including timestamps and authorisation codes, returned to l89v by bKash, Nagad, Rocket, Upay, and banking partners following a deposit or withdrawal instruction.
• Fraud prevention agencies: In cases of suspected fraud or money laundering, l89v may receive flagging data from third-party risk intelligence services. This data is used exclusively for account security and compliance purposes.

5 Purpose and Legal Basis for Processing

l89v processes your personal data only where there is a lawful basis for doing so. The table below summarises the primary purposes for which we process personal data and the corresponding legal basis for each purpose.

Where l89v relies on legitimate interest as the legal basis for processing, we have assessed that our legitimate interest is not overridden by your privacy rights and interests. You may request further information about this balancing assessment by contacting the l89v Privacy Team.

Where processing is based on your consent — primarily for receiving marketing and promotional communications — you may withdraw that consent at any time by adjusting your notification preferences in your account settings or by contacting support. Withdrawal of consent does not affect the lawfulness of any processing carried out before the withdrawal.

6 Sharing Your Personal Data

l89v does not sell, rent, or trade your personal data to any third party. We share personal data with third parties only in the limited circumstances described below, and only to the minimum extent necessary for the stated purpose.

6.1 Payment Processors

To process your deposit and withdrawal instructions, l89v shares the relevant identity and financial data with our payment processing partners, including bKash, Nagad, Rocket, Upay, Visa/Mastercard acquiring banks, and Dutch-Bangla Bank. These partners are contractually restricted from using your data for any purpose other than completing the specific transaction.

6.2 KYC and Identity Verification Providers

For the purpose of verifying your identity as required by our anti-money laundering compliance obligations, l89v transmits copies of your submitted identity documents to our contracted KYC verification service providers. These providers process the data solely for verification purposes and are prohibited from retaining document images beyond the period necessary to complete the check.

6.3 Game Studios and Software Providers

When you play games provided by third-party studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, or Ezugi, session data — including your player identifier and bet history for the relevant session — is transmitted to the game provider's servers to enable real-time gameplay. These providers do not receive your full identity or financial data.

6.4 Fraud Prevention and Risk Intelligence Services

In cases of suspected fraud, money laundering, or prohibited conduct, l89v may share relevant account and transaction data with third-party fraud prevention agencies. This sharing is conducted on the basis of our legitimate interest in protecting the platform and complying with applicable law.

6.5 Legal and Regulatory Authorities

l89v will disclose personal data to law enforcement agencies, regulatory bodies, or courts where we are legally compelled to do so by a valid legal instrument, or where disclosure is necessary to protect the rights, property, or safety of l89v, its players, or the public. l89v will notify the affected player of any such disclosure request unless legally prohibited from doing so.

6.6 Corporate Transactions

In the event of a merger, acquisition, or sale of all or part of l89v's business assets, personal data held by l89v may be transferred to the acquiring entity as part of that transaction. Players will be notified of any such transfer and of any material changes to this Policy that result from it, with a minimum of 30 days' notice before the transfer takes effect.

7 Data Retention

l89v retains personal data for no longer than is necessary to fulfil the purposes for which it was collected, subject to any overriding legal obligations that require longer retention periods. The following retention periods apply:

• Account and identity data: Retained for 7 years after the date of account closure. This period is required to satisfy anti-money laundering record-keeping obligations.
• Transaction and financial data: Retained for 7 years from the date of each transaction, consistent with standard financial record-keeping requirements.
• Gaming and betting history: Retained for 5 years from the date of account closure for responsible gaming monitoring and dispute resolution purposes.
• Customer support communications: Retained for 3 years from the date of the final message in each support case.
• Session and technical logs: Retained on a rolling 90-day basis, after which they are permanently deleted.
• Marketing consent records: Retained until consent is withdrawn, plus 3 years thereafter as evidence of the consent transaction.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised using industry-standard methods that render re-identification impossible. Anonymised, aggregated data may be retained indefinitely for statistical and analytical purposes.

8 Security Measures

l89v implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security programme includes but is not limited to the following measures:

• 256-bit SSL/TLS encryption for all data in transit between your device and l89v servers
• AES-256 encryption for sensitive personal data stored at rest in our databases
• Multi-factor authentication requirements for all internal staff accounts with access to player data
• Role-based access controls that restrict employee access to personal data on a strict need-to-know basis
• Regular third-party penetration testing and vulnerability assessments of the Platform infrastructure
• Continuous monitoring systems that generate automated alerts for anomalous access patterns
• Annual information security training for all employees who handle personal data
• A documented incident response plan that includes player notification procedures in the event of a data breach

9 Cookies and Tracking Technologies

l89v uses cookies and similar tracking technologies on the Platform to provide a functional and consistent user experience. The following categories of cookies are in use:

9.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function. They maintain your login session, enforce security controls, and remember your language and display preferences. These cookies cannot be disabled without preventing core Platform functionality from working. No consent is required for strictly necessary cookies.

9.2 Analytics Cookies

l89v uses first-party analytics cookies to collect aggregate, anonymised data about how players navigate and use the Platform. This data helps us identify technical errors, understand which features are most valuable, and prioritise Platform improvements. Analytics cookies do not identify you personally and the data collected is never shared with third-party advertising networks.

9.3 Functional Cookies

Functional cookies remember your voluntary preferences on the Platform, such as your preferred game category, default deposit method, and notification settings. Disabling these cookies means that your preferences will not be saved between sessions, but it will not prevent you from using the Platform.

9.4 What We Do Not Use

l89v does not use advertising cookies, retargeting cookies, or any third-party tracking technologies that profile your behaviour across websites outside the l89v Platform. We do not participate in programmatic advertising networks or sell cookie-derived audience segments to any third party.

You may manage or delete cookies through your browser settings at any time. Please note that deleting strictly necessary cookies will require you to log in again on your next visit.

10 Your Privacy Rights

As a player on the l89v Platform, you hold the following rights in respect of your personal data. All rights may be exercised free of charge by contacting the l89v Privacy Team at the address given in Section 13. l89v will respond to all valid requests within 30 days.

11 Children's Privacy

The l89v Platform is strictly intended for adults aged 21 and above. l89v does not knowingly collect personal data from any individual under the age of 21. Registration requires confirmation of age, and l89v conducts KYC age verification checks on all accounts before permitting withdrawals.

If l89v becomes aware that personal data has been collected from a person under the age of 21 — whether through a false age declaration or any other means — the relevant account will be immediately suspended, all funds will be reviewed in accordance with our Terms and Conditions, and the data will be securely deleted as soon as the investigation is concluded.

If you are a parent or guardian and believe that a minor in your care has created an l89v account, please contact our support team immediately so that we can investigate and take appropriate action.

12 Changes to This Privacy Policy

l89v reserves the right to update or amend this Privacy Policy at any time. Material changes — defined as changes that affect the categories of data collected, the purposes for which data is used, or the rights available to players — will be communicated to registered players via their registered mobile number or email address at least 14 days before the changes take effect.

Minor clarifications and formatting changes that do not alter the substance of the Policy may be published without advance notice. The "Effective Date" at the top of this page and in the hero section will be updated each time the Policy is revised. We encourage you to review this Policy periodically to stay informed of how l89v protects your data.

Your continued use of the Platform after the effective date of any material amendment constitutes your acceptance of the revised Policy. If you do not agree with the revised Policy, you may close your account and request deletion of your data subject to the retention obligations in Section 7.

13 Contact Us

For all privacy-related enquiries, subject access requests, complaints, or requests to exercise your data rights, please contact the l89v Privacy Team. We are committed to resolving all privacy concerns promptly and transparently.

Privacy Team contact: [email protected] — please note this address is displayed as plain text only and is not a clickable link. Include "Privacy Request" in the subject line of your correspondence, along with your registered username and a clear description of your enquiry.

l89v aims to acknowledge all privacy-related correspondence within 5 business days and to provide a substantive response within 30 calendar days of receiving a verified request. All correspondence is handled in English and during Bangladesh Standard Time (BST, UTC+6) business hours.