Your Privacy Matters at 89bd1 — How We Protect Your Data

1. Data Controller

89bd1 operates as the data controller in respect of all personal data collected from users of the platform. As data controller, 89bd1 determines the purposes and means by which personal data is processed and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

All data-related enquiries, access requests, and complaints should be directed to the 89bd1 Data Protection team using the contact details provided in Section 14 of this policy. We aim to acknowledge all data-related correspondence within 5 business days (Bangladesh Standard Time, UTC+6) and to resolve requests fully within 30 calendar days.

2. Personal Data We Collect

89bd1 collects personal data across several categories depending on your level of engagement with the platform. The table below summarises the categories of data collected, with examples and the context in which each category is obtained.

89bd1 does not collect special categories of sensitive personal data (such as health data, racial or ethnic origin, religious beliefs, or biometric data) unless this is strictly required to fulfil a compliance obligation, in which case you will be specifically notified and your explicit consent obtained.

3. How We Collect Your Data

3.1 Directly from You

The majority of personal data 89bd1 holds about you is provided directly by you through your interactions with the platform. This includes data submitted during the account registration process, information provided when completing KYC verification, details entered when making a deposit or requesting a withdrawal, content shared during live chat or email support conversations, and responses to surveys or promotional opt-ins.

3.2 Automatically from Your Device

When you access the 89bd1 platform, certain technical data is collected automatically. This includes your IP address, the type and version of your web browser, the device you are using (desktop, mobile, tablet), your operating system, the pages you visit within the platform, the time and duration of your sessions, and referral source information. This data is collected using server logs, cookies, and similar tracking technologies described further in Section 8.

3.3 From Third-Party Partners

89bd1 may receive personal data about you from third-party service providers in certain circumstances. These include identity verification and KYC service providers (who share verification outcomes and risk scores), payment processors (who confirm transaction statuses and flag payment method ownership issues), anti-fraud and AML screening platforms, and game providers (who may share session and game-outcome data for dispute resolution and responsible gaming monitoring purposes).

4. Purposes of Processing

89bd1 processes your personal data for the following purposes. Each purpose is linked to a specific legal basis outlined in Section 5.

• Account Management: To create, maintain, verify, and close your registered Account, including processing name, contact, and authentication data.
• Identity Verification (KYC): To confirm your identity, age (21+), and address in compliance with our responsible gaming and anti-money-laundering obligations before allowing withdrawals or when triggered by compliance thresholds.
• Payment Processing: To facilitate deposits via bKash, Nagad, Rocket, Upay, and bank transfer, and to process withdrawal requests to verified payment accounts in Bangladeshi Taka (BDT).
• Fraud Prevention and AML Compliance: To detect, investigate, and prevent fraudulent activity, bonus abuse, money laundering, and other financial crimes on the platform.
• Responsible Gaming: To monitor gaming behaviour, enforce deposit limits and self-exclusion arrangements, and identify players who may be displaying signs of problem gambling.
• Customer Support: To respond to your queries, complaints, and requests submitted via live chat, email, or any other support channel.
• Platform Improvement: To analyse usage patterns and technical performance data in order to improve the platform's features, content, and user experience.
• Marketing Communications: To send promotional offers, bonus notifications, and platform updates to players who have opted in to marketing communications. Opt-out is available at any time.
• Legal Compliance: To retain transaction and identity records for the periods required by applicable law, and to respond to lawful requests from competent authorities.

5. Legal Basis for Processing

89bd1 processes personal data under the following legal bases, consistent with internationally recognised data protection principles:

• Contractual Necessity: Processing that is necessary to perform the contract between 89bd1 and you (i.e., the Terms & Conditions you accepted at registration). This covers Account management, payment processing, and the delivery of betting and gaming services.
• Legal Obligation: Processing required to comply with applicable laws and regulations. This covers KYC verification, AML screening, transaction record retention, and responding to lawful requests from law enforcement or financial intelligence authorities.
• Legitimate Interests: Processing that is necessary for 89bd1's legitimate business interests, provided those interests are not overridden by your data protection rights. This covers fraud prevention, platform security monitoring, responsible gaming analytics, and technical performance analysis.
• Consent: Processing for which you have given clear, informed, and freely withdrawable consent. This covers marketing communications and any analytics cookies beyond strictly essential session cookies. You may withdraw consent at any time without affecting the lawfulness of processing that occurred prior to withdrawal.

6. Data Sharing and Third Parties

6.1 Categories of Recipients

89bd1 shares your personal data only with the categories of third parties listed below, and only to the extent strictly necessary for the stated purpose. All third-party recipients are bound by data processing agreements that require them to protect your data and use it solely for the specified purpose.

• KYC and Identity Verification Providers: To verify your identity, age, and address during the KYC process. Verification outcomes and risk indicators are shared back to 89bd1; your raw documents are processed by the KYC provider under strict data handling obligations.
• Payment Processors: bKash, Nagad, Rocket, Upay, and banking partners receive the transaction data required to execute deposits and withdrawals. Payment account numbers are shared with the relevant payment provider only for the specific transaction concerned.
• Game Providers: Studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi receive session identifiers and game-play data necessary to operate their games on the 89bd1 platform. These providers do not receive your full identity data.
• Fraud Prevention and AML Platforms: Transaction and identity data may be submitted to third-party screening platforms to detect financial crime patterns. These platforms are contractually prohibited from retaining your data beyond the screening purpose.
• IT and Infrastructure Providers: Cloud hosting, data backup, and platform operations providers may process technical data on 89bd1's behalf as data processors under binding agreements.
• Legal and Regulatory Authorities: 89bd1 will disclose personal data to law enforcement, financial intelligence units, or other competent authorities when required to do so by law, court order, or legitimate regulatory request.

6.2 No Sale of Data

89bd1 does not sell, rent, or otherwise commercially exploit your personal data to any third party. Any transfer of data to a third party is made solely to deliver services to you or to fulfil a legal obligation, never for the third party's independent marketing or commercial purposes.

7. Data Retention

89bd1 retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or for as long as required by applicable legal obligations. The table below outlines our standard retention periods by data category.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be linked to an identifiable individual. Anonymised data may be retained indefinitely for statistical and platform improvement purposes.

8. Cookies and Tracking Technologies

8.1 What Are Cookies?

Cookies are small text files placed on your device by a website when you visit it. They allow the website to recognise your device on subsequent visits, maintain your session state, remember your preferences, and collect aggregated analytics data about how visitors use the platform.

8.2 Types of Cookies Used by 89bd1

• Strictly Necessary Cookies: Essential for the platform to function correctly. These include session authentication tokens, load balancing cookies, and security cookies. These cookies cannot be disabled without severely impairing your ability to use the platform.
• Functional Cookies: Remember your preferences such as language settings, display preferences, and notification opt-in status. These are not strictly required but significantly improve your experience.
• Analytics Cookies: Used to collect aggregated, anonymised data about how visitors navigate and interact with the 89bd1 platform, which pages attract the most traffic, and where technical errors occur. This data is used solely to improve the platform.
• Responsible Gaming Cookies: Track session duration and activity patterns as part of 89bd1's responsible gaming monitoring system. These cookies support the session time reminders and cooling-off enforcement features.

8.3 Third-Party Cookies

89bd1 does not permit third-party advertising networks or social media platforms to place tracking cookies on the 89bd1 platform. Game providers may set session cookies strictly necessary to deliver their games within the platform environment; these cookies expire at the end of your gaming session.

8.4 Managing Cookies

You may manage and delete cookies through your browser settings at any time. Disabling strictly necessary cookies will prevent you from logging in and using core platform features. Disabling analytics or functional cookies will not affect your ability to play but may reduce the quality of your browsing experience. For detailed instructions on managing cookies in your specific browser, please consult your browser's help documentation.

9. Your Data Protection Rights

As a user of the 89bd1 platform, you hold the following rights with respect to your personal data. To exercise any of these rights, please contact the 89bd1 Data Protection team using the details in Section 14. We will respond within 30 calendar days of receiving a valid request.

• Right of Access: You may request a copy of all personal data that 89bd1 holds about you, together with information about how it is processed and on what legal basis.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected without undue delay. Basic profile information may be updated directly through your Account settings panel.
• Right to Erasure ("Right to be Forgotten"): You may request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent (and no other legal basis applies), or where the data has been unlawfully processed. Note that legal retention obligations (see Section 7) may prevent the immediate deletion of certain categories of data.
• Right to Restrict Processing: You may request that 89bd1 restrict the processing of your data in certain circumstances, such as while the accuracy of data is being contested or while an objection to processing is being assessed.
• Right to Data Portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to have it transmitted to another data controller where technically feasible.
• Right to Object: You have the right to object to processing based on legitimate interests or for direct marketing purposes. Where you object to direct marketing, processing for that purpose will cease immediately. For other legitimate interests objections, 89bd1 will assess whether its interests override your rights.
• 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 prior to the withdrawal.

10. Data Security

89bd1 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Encryption in Transit: All data transmitted between your device and the 89bd1 platform is protected by TLS 1.2 or higher (SSL) encryption, ensuring that data cannot be intercepted or read by third parties during transmission.
• Encryption at Rest: Sensitive personal data stored in 89bd1's databases is encrypted using AES-256 encryption. Financial credentials such as payment account references are additionally hashed using one-way cryptographic functions.
• Access Controls: Access to personal data within 89bd1's internal systems is restricted on a strict need-to-know basis. Staff members are granted access only to the categories of data required to perform their specific role. All internal data access is logged and audited.
• Regular Security Audits: 89bd1 conducts regular internal security reviews and periodic third-party penetration testing to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: 89bd1 maintains a documented data breach response plan. In the event of a data breach that poses a risk to your rights and freedoms, affected users will be notified promptly with details of the breach, the data affected, and the steps being taken to address it.
• Staff Training: All 89bd1 staff who handle personal data receive regular data protection training and are bound by confidentiality obligations that form part of their employment contracts.

While 89bd1 takes all reasonable steps to protect your data, no digital platform can guarantee absolute security. You play an important role in protecting your own data — please use a strong, unique password for your 89bd1 Account and do not share your login credentials with anyone.

11. Children's Privacy and the 21+ Policy

89bd1 operates a strict minimum age policy of 21 years. The platform is not intended for, and does not knowingly collect personal data from, individuals below the age of 21. Age verification is a mandatory component of the registration and KYC process.

If 89bd1 discovers or has reasonable grounds to believe that personal data has been collected from a person under the age of 21, the Account will be immediately suspended, all associated funds will be frozen pending investigation, and any personal data collected will be deleted in accordance with applicable legal requirements. A full investigation will be conducted to determine how the underage registration occurred, and steps will be taken to prevent recurrence.

If you are a parent or guardian and have reason to believe that your child has registered on the 89bd1 platform, please contact our support team immediately via live chat or at the email address listed in Section 14. We will act on all such reports promptly.

12. Third-Party Links and External Services

The 89bd1 platform may contain references to third-party game providers and payment services. While 89bd1 carefully selects its partners and requires them to maintain appropriate data protection standards under contractual obligations, 89bd1 is not responsible for the privacy practices of third-party services operating their own platforms independently of 89bd1.io.

Game provider software interfaces (such as those delivered by Pragmatic Play, Evolution Gaming, Spribe, and others) operate within the 89bd1 platform environment. The data these providers access is governed by the data processing agreements between 89bd1 and each provider. Players do not hold a direct contractual relationship with game providers through the 89bd1 platform.

Payment service providers including bKash, Nagad, Rocket, and Upay operate under their own terms of service and privacy policies when processing transactions. 89bd1 shares only the data strictly necessary to execute your transaction. We encourage you to review the privacy policies of your chosen payment provider directly through their official channels.

13. Updates to This Privacy Policy

89bd1 reviews and updates this Privacy Policy at least once every 12 months and whenever there is a material change in our data processing activities, applicable legal requirements, or the services we offer. The effective date displayed at the top of this document reflects the date of the most recent update.

When material changes are made to this Privacy Policy, registered players will be notified via email or through a prominent notice on the platform at least 7 days before the changes take effect. For minor clarifications or non-material updates, the revised policy will be published on this page without advance notification, though the effective date will be updated accordingly.

Your continued use of the 89bd1 platform following any update to this Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the updated policy, you should cease using the platform and request Account closure through our support team before the updated policy takes effect.

14. Contact Information

For all privacy-related enquiries, data access requests, complaints, or to exercise any of your data protection rights, please contact the 89bd1 Data Protection team through the following channels:

• Live Chat: Available 24/7 via the 89bd1 platform — average response time 2–5 minutes. Select "Data & Privacy" as the enquiry type when prompted.
• Email: [email protected] — please use the subject line "Privacy Request" and include your registered Account username to allow us to locate your records promptly. (Plain text — not a clickable link; copy the address manually.)
• Response Time: We aim to acknowledge all privacy requests within 5 business days and to resolve them fully within 30 calendar days. Complex requests or those requiring third-party coordination may require up to 45 days, in which case we will notify you of the extended timeline.
• Business Hours: Our Data Protection team operates Monday to Saturday, 9:00 AM – 9:00 PM Bangladesh Standard Time (BST, UTC+6). Live chat support is available 24/7 for urgent enquiries outside these hours.