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Legal Document

ll89 Privacy Policy

Your privacy matters to us. This document explains exactly what personal data ll89 collects, why we collect it, and the rights you hold as a registered player in Bangladesh.

📅 Effective Date: January 1, 2026 — Last reviewed January 2026

ll89 operates the online casino and sports betting platform accessible at ll89.club. In the course of providing our services to players in Bangladesh, we collect and process certain personal data. This Privacy Policy ("Policy") describes our data practices in plain language so that you can make informed decisions about your use of the ll89 platform.

By registering an account on ll89 or by continuing to use the platform, you acknowledge that you have read and understood this Policy and that you agree to the collection and use of your personal data as described herein. If you do not agree, please discontinue use of the ll89 platform and contact our support team to close your account.

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SSL Encrypted
All data transmitted between your device and ll89 servers is protected by SSL encryption at all times.
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No Data Selling
ll89 never sells or rents your personal data to any third-party advertiser or data broker.
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Transparency First
We tell you exactly what we collect, why we collect it, and who we may share it with — no hidden clauses.
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Your Data Rights
You have the right to access, correct, delete, and port your personal data. Contact support to exercise any right.
Important: This Policy applies solely to personal data processed by ll89 in connection with the ll89.club platform. It does not apply to third-party websites, applications, or services that may be linked from the ll89 platform. ll89 is not responsible for the privacy practices of any third party.

1 Information We Collect

ll89 collects personal data through several channels: directly from you when you register and use the platform, automatically as you interact with the site, and from payment service providers when you make financial transactions. The categories of personal data we collect are set out below.

Identity Data
Full name, date of birth, gender, and scanned copies of government-issued identity documents (National ID / NID, passport) collected during account registration and KYC verification. This data is used to confirm your identity and verify that you meet the 21+ age requirement.
Contact Data
Mobile phone number (required for account creation and OTP-based verification), email address (where provided), and Telegram username (where you choose to contact support via Telegram). Your mobile number is the primary identifier linked to your ll89 account and your registered payment methods (bKash, Nagad, Rocket).
Financial Data
Records of all deposits, withdrawals, and wagering activity on your account, including transaction reference numbers, transaction timestamps (in Bangladesh Standard Time, UTC+6), amounts in BDT, and the payment method used. Full payment credentials (bKash PIN, bank passwords) are never stored on ll89 servers; transactions are processed directly by the respective payment gateways.
Technical Data
IP address, device type and model, operating system version, browser type and version, screen resolution, session duration, pages visited, referring URL, and approximate geolocation (country and city level, derived from IP address). This data is collected automatically each time you access ll89 and is used for security monitoring, fraud detection, and platform optimisation.
Communications Data
Records of all communications between you and the ll89 support team, including Telegram chat logs, email correspondence, and any documents you submit in connection with a support request or a complaint. Communication records are retained for quality assurance, dispute resolution, and regulatory compliance purposes.

ll89 does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data. If in the future any additional categories of data are collected, this Policy will be updated and you will be notified.

2 How We Use Your Information

ll89 uses your personal data only for the purposes described in this Policy. We do not use your data for purposes that are incompatible with those stated below. The main purposes for which we use your personal data are:

  • Account creation and management: To register your account, verify your identity and age (KYC), maintain your wallet balance, and provide access to all gaming and sports betting services available on ll89.
  • Payment processing: To process your deposits and withdrawals via bKash, Nagad, Rocket, Upay, and bank transfer, to maintain accurate financial records, and to comply with anti-money-laundering (AML) obligations.
  • Security and fraud prevention: To monitor account activity for signs of unauthorised access, bonus abuse, collusion, money laundering, and other prohibited conduct. Technical data including IP addresses and device fingerprints are used for this purpose.
  • Responsible gaming: To apply and enforce deposit limits, time-out restrictions, and self-exclusion orders that you have requested, and to identify account usage patterns that may indicate problem gambling behaviour, so that ll89 can intervene proactively.
  • Customer support: To respond to your queries, process complaints, investigate disputes, and provide assistance in both English and Bangla through our Telegram and email support channels.
  • Platform improvement: To analyse aggregated, anonymised usage data (page visit frequencies, session lengths, feature usage rates) to improve the platform's performance, content, and user experience. Individual players are never identified in this analysis.
  • Marketing communications: To send you promotional offers, bonus notifications, and platform updates by SMS or Telegram — but only where you have opted in to receive such communications during registration or subsequently. You may opt out at any time by contacting support.
No Profiling for Advertising: ll89 does not build advertising profiles from your personal data and does not share your data with any advertising networks, social media platforms, or data brokers for targeted advertising purposes. Any marketing you receive from ll89 is based solely on your activity and preferences within the ll89 platform itself.

3 Legal Basis for Processing

ll89 processes your personal data only where it has a lawful basis to do so. The lawful bases we rely on for our data processing activities are:

  • Contract performance: The majority of the data processing described in this Policy is necessary to provide you with the services you have contracted for when registering an ll89 account — specifically account management, gaming services, and payment processing.
  • Legitimate interests: Security monitoring, fraud detection, platform improvement, and responsible gaming interventions are conducted in ll89's legitimate interest in operating a secure, fair, and responsible gaming platform. These interests do not override your fundamental privacy rights.
  • Legal obligation: KYC identity verification, AML transaction monitoring, and retention of financial records are carried out to comply with applicable legal obligations. ll89 may be required to disclose data to competent authorities where required by law.
  • Consent: Where we send you optional marketing communications, we rely on your freely given, specific, informed, and unambiguous consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out before withdrawal.

4 Sharing Your Information

ll89 does not sell, trade, or rent your personal data. We share your data only in the limited circumstances described below, and only to the extent strictly necessary for each purpose:

  • Payment service providers: We share the minimum personal data required by bKash, Nagad, Rocket, Upay, and other payment processors to authenticate and complete your deposit and withdrawal transactions. These providers process your data under their own privacy policies and are bound by contractual data-protection obligations with ll89.
  • Technology and infrastructure providers: ll89 uses third-party hosting, database, and security service providers to operate the platform. These providers act as data processors and handle your personal data only on ll89's documented instructions. They are contractually prohibited from using your data for their own purposes.
  • Game software providers: Some games on ll89 are provided by third-party studios such as Pragmatic Play, Evolution Gaming, Spribe, and Ezugi. To deliver their games, these studios may receive your player ID and session data. They do not receive your name, phone number, payment details, or identity documents.
  • Legal and regulatory authorities: Where required by applicable law, court order, or regulatory authority in Bangladesh or any other competent jurisdiction, ll89 may disclose personal data to law enforcement agencies, financial intelligence units, or other government bodies. ll89 will notify you of any such disclosure where permitted to do so by law.

In the event of a business transfer — such as a merger, acquisition, or sale of all or part of ll89's business — your personal data may be transferred to the acquiring entity as part of the transaction, subject to equivalent privacy protections being maintained. You will be notified of any such transfer in advance.

Our Promise: ll89 will never sell, license, or give away your personal data to any third party for their own marketing or commercial purposes. Every data-sharing arrangement described in this Policy is either operationally necessary, legally compelled, or explicitly consented to by you.

5 Cookies and Tracking Technologies

ll89 uses cookies and similar tracking technologies to operate the platform, maintain your login session, and collect the technical data described in Section 1. The types of cookies we use are:

  • Essential cookies: These are strictly necessary to deliver the core functions of the ll89 platform, including session authentication, wallet access, and game loading. The platform cannot function without these cookies. They are set automatically when you access ll89 and cannot be disabled without preventing use of the platform.
  • Analytics cookies: These collect aggregated, anonymised data about how players navigate and use the ll89 platform. This information is used internally to identify usability issues and improve the platform. No individual player is identified through analytics data.
  • Security cookies: These are used to detect and prevent fraudulent activity, bot traffic, and account-takeover attempts. They record device characteristics and behavioural patterns to distinguish legitimate players from automated threats.
  • Preference cookies: These remember your language selection and other platform preferences between sessions so that you do not need to reset them each time you visit.

Most modern browsers allow you to control cookie settings through the browser's privacy or settings menu. You may choose to block or delete cookies at any time; however, doing so may impair the functionality of the ll89 platform, including your ability to log in and access your account. ll89 does not use cross-site tracking cookies or advertising cookies.

6 Data Retention

ll89 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law, whichever period is longer. The following retention periods apply:

Account data and KYC documents are retained for the duration of your active account plus a minimum of 5 years after account closure, in line with standard AML record-keeping obligations. Financial transaction records are retained for a minimum of 7 years after the date of each transaction. Communication records are retained for 2 years from the date of last communication. Technical and log data used for security purposes is retained for 12 months. Anonymised analytics data may be retained indefinitely as it cannot be linked back to any individual.

Deletion on Request: Subject to the mandatory minimum retention periods described above, you may request deletion of your personal data at any time by contacting ll89 support. ll89 will process verified deletion requests within 30 days and will confirm completion in writing. Data subject to a legal hold or active investigation cannot be deleted until the hold or investigation is resolved.

7 Data Security

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

  • SSL/TLS encryption on all data transmissions between your browser or mobile device and ll89 servers, ensuring that your login credentials, payment details, and personal information cannot be intercepted in transit.
  • Encryption at rest for sensitive personal data stored on ll89 databases. Payment credentials and identity document images are stored in encrypted form and access is restricted to authorised personnel only, on a strict need-to-know basis.
  • Multi-factor authentication controls on all internal ll89 systems that contain personal data. Staff access to production data is logged and audited. Access rights are reviewed and recertified on a regular basis.
  • Ongoing monitoring for suspicious access patterns, data exfiltration attempts, and other security incidents. ll89 maintains an incident response procedure to contain, investigate, and remediate any security breach in the shortest possible time.

While ll89 employs industry-standard security measures, no online platform can guarantee absolute security. In the unlikely event of a data breach that poses a high risk to your rights and freedoms, ll89 will notify affected players without undue delay and will take all reasonably practicable steps to mitigate the impact of the breach.

8 Your Data Rights

As a registered user of ll89, you hold the following rights in relation to your personal data. You may exercise any of these rights at any time by contacting ll89 support via Telegram (@ll89support) or by email. ll89 will respond to verified rights requests within 30 days.

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Right to Access
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Right to Rectification
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Right to Erasure
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Right to Restrict Processing
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Right to Data Portability
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Right to Withdraw Consent

To exercise any of the rights listed above, please contact our support team. ll89 will verify your identity before processing any data rights request to ensure that personal data is not disclosed to, amended by, or deleted on the instruction of an unauthorised third party. Identity verification for rights requests may require you to provide a copy of your registered NID or other government-issued document.

Email for data rights requests (plain text only):

9 Children's Privacy

The ll89 platform is strictly intended for adults aged 21 and above. ll89 does not knowingly collect, process, or store personal data relating to any individual under the age of 21. Age verification is a core part of the ll89 registration process, and all accounts are subject to KYC checks that include confirmation of date of birth.

If ll89 becomes aware that personal data has been collected from or in relation to an individual who is under 21 years of age, we will take immediate steps to delete that data, close the associated account, and return any real-money balance to the payment source from which it originated, subject to verification.

Report Underage Access: If you believe that a person under 21 years of age has registered on or is using ll89, please report this to our support team immediately via Telegram (@ll89support). We take all underage access reports seriously and will investigate promptly.

10 Payment Data and Financial Privacy

When you make a deposit or withdrawal on ll89 using bKash, Nagad, Rocket, Upay, or bank transfer, the financial transaction is processed directly by the respective payment service provider. ll89 receives confirmation of the transaction (amount, timestamp, reference number, and masked sender identifier) but does not receive or store your full mobile banking PIN, OTP codes, bank account password, or card details. ll89 has no access to the credentials used to authenticate transactions on the payment provider's side.

All financial transaction records on ll89 are retained in accordance with the data retention periods described in Section 6 of this Policy. Transaction records may be accessed by ll89's compliance team for the purposes of AML monitoring, dispute resolution, and responding to lawful requests from regulatory authorities. Players may request a copy of their own transaction history at any time by contacting ll89 support.

11 Third-Party Services and Links

The ll89 platform integrates third-party game content provided by studios including Pragmatic Play, Evolution Gaming, Spribe, Ezugi, and Microgaming. When you play a game provided by one of these studios, the game client may communicate directly with the studio's servers. ll89 has data-processing agreements in place with all integrated studios that restrict the data those studios may collect and prohibit them from using player data for their own commercial purposes beyond game delivery.

ll89 is not responsible for the privacy practices of third-party game studios, payment providers, or any external service whose own terms and privacy notices govern your interactions with those services. We encourage you to review the privacy policies of any third-party service you interact with in connection with your ll89 experience.

12 Updates to This Privacy Policy

ll89 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or the services we offer. When we make material changes, we will update the Effective Date at the top of this document. Where a change significantly affects your rights or the way we handle your data, we will endeavour to notify you directly through our primary support channel (Telegram) before the change takes effect.

The current version of this Privacy Policy is always the governing version. Continued use of ll89 after any update to this Policy constitutes your acknowledgement of the updated Policy. If you do not agree with any update to this Policy, you have the right to close your account and request deletion of your personal data as described in Section 8.

Version History: This is version 1.0 of the ll89 Privacy Policy, effective January 1, 2026. ll89 will maintain a version history of this Policy and prior versions will be available on request from the support team.

13 Contact Our Privacy Team

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or have a concern about how ll89 has handled your personal data, please contact our support team. We are available 24 hours a day, 7 days a week, in both English and Bangla.

Email (plain text — not a clickable link):

Telegram: @ll89support

Our support team will acknowledge your privacy enquiry within 2 hours and provide a full response within 30 days as required for data rights requests. For urgent security concerns — such as suspected unauthorised access to your account — please contact us immediately via Telegram for the fastest response.

Questions About Your Privacy?

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