ld89 Privacy Policy

Introduction

ld89 ("we", "us", "our") operates the online casino and sports betting platform accessible at ld89.io (the "Platform"). We are committed to safeguarding the privacy of every individual who visits, registers on, or interacts with the Platform. This Privacy Policy describes the personal data we collect, the purposes for which it is processed, the parties with whom it may be shared, and the rights available to you as a data subject.

This Privacy Policy applies to all users of the ld89 Platform, including registered Players, visitors who browse without registering, and individuals who contact our support team. It should be read together with the ld89 Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

By accessing the Platform or creating a registered account, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree with any part of this Policy, please discontinue use of the Platform and contact us to request account closure.

Personal Data We Collect

ld89 collects personal data from you through several channels: directly when you register or interact with our services, automatically when you use the Platform, and from third parties such as payment processors and identity verification providers. The categories of personal data we collect are set out below.

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health information unless this is voluntarily provided in the context of a responsible gaming support request, in which case it is handled with the highest level of care and confidentiality.

How We Use Your Personal Data

ld89 processes your personal data only for specific, legitimate purposes that are directly connected to operating the Platform and maintaining a safe, compliant gaming environment for all Bangladesh players. We do not process your data in ways that are incompatible with those original purposes.

• Account Management: To create, maintain, verify, and administer your registered ld89 account, including password resets and account security checks.
• Identity Verification (KYC): To verify that you are 21 years of age or older and that your identity matches the details provided at registration, as required by responsible gaming standards.
• Transaction Processing: To process deposits via bKash, Nagad, Rocket, Upay, and partner banks, and to facilitate withdrawal requests to your verified payment method.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, bonus abuse, multiple account creation, and other security threats.
• Customer Support: To respond to your enquiries, resolve disputes, process complaints, and provide assistance through our 24/7 English support team.
• Platform Improvement: To analyse usage patterns, understand player preferences, identify technical issues, and continually improve the quality of the ld89 experience.
• Responsible Gaming: To monitor gameplay patterns for signs of problem gambling, enforce self-exclusion orders, apply deposit and loss limits, and fulfil our responsible gaming obligations.
• Legal Compliance: To comply with applicable laws, respond to lawful requests from regulatory and law enforcement authorities, and enforce our Terms & Conditions.
• Marketing Communications: To send you promotional offers, bonus notifications, and news about ld89 — but only where you have provided explicit consent and have not subsequently opted out.

Legal Basis for Processing

ld89 processes personal data on one or more of the following legal bases, depending on the specific processing activity involved:

• Contractual Necessity: Processing that is necessary to perform the contract between ld89 and the Player, including account creation, transaction processing, and support provision.
• Legal Obligation: Processing that is required to comply with applicable legal and regulatory obligations, including KYC verification, anti-money laundering checks, and responding to lawful authority requests.
• Legitimate Interests: Processing that is necessary for ld89's legitimate business interests, such as fraud prevention, platform security, analytics, and responsible gaming monitoring, provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing that is based on your freely given, specific, informed, and unambiguous consent — primarily in the context of direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Data Sharing & Third-Party Disclosure

ld89 does not sell, rent, or otherwise transfer your personal data to unaffiliated third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank, Visa, and Mastercard — to facilitate deposits and withdrawals. Each processor operates under its own privacy policy and is bound by contractual data protection obligations.
• Identity Verification Providers: Third-party KYC and age verification service providers used to authenticate your identity documents and confirm your eligibility to register.
• Game Content Providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and other licensed studios whose games are hosted on the Platform. These providers may receive anonymised session data for game integrity and fair-play auditing purposes.
• IT Infrastructure Providers: Cloud hosting, server management, and cybersecurity providers who process data on our behalf under strict data processing agreements.
• Analytics Providers: Web analytics platforms used to understand aggregated, anonymised usage trends on the Platform. No individually identifiable data is shared with analytics providers for advertising targeting purposes.
• Legal and Regulatory Authorities: Courts, law enforcement agencies, financial intelligence units, and other competent authorities, where disclosure is required by applicable law, court order, or regulatory directive.
• Professional Advisers: Lawyers, auditors, accountants, and insurers who require access to your data in connection with the provision of professional services to ld89, subject to confidentiality obligations.

All third parties with whom ld89 shares personal data are contractually required to maintain the confidentiality and security of that data and to use it only for the specific purposes for which it was disclosed.

Cookies & Tracking Technologies

ld89 uses cookies and similar tracking technologies to operate the Platform, maintain your session state, and gather anonymised analytics data. Cookies are small text files placed on your device when you visit the Platform. They do not contain malicious code and cannot access other files on your device.

The categories of cookies used by ld89 are as follows:

• Strictly Necessary Cookies: Essential to the operation of the Platform. These cookies enable you to log in, maintain your session, and use core platform features. They cannot be disabled without affecting Platform functionality.
• Performance and Analytics Cookies: Used to collect anonymised data about how visitors use the Platform, including pages visited, time spent, and navigation paths. This data is used solely to improve Platform performance and user experience.
• Functional Cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalised experience on return visits.

ld89 does not use advertising cookies, retargeting cookies, or third-party tracking pixels that share your browsing behaviour with external advertising networks. You may manage or delete cookies through your browser settings; however, disabling strictly necessary cookies will impair your ability to use the Platform.

Data Retention

ld89 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, unless a longer retention period is required by applicable law or regulation. The following general retention periods apply:

• Account Data: Retained for the duration of your active account plus a minimum of five (5) years following account closure, in compliance with anti-money laundering and responsible gaming record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of seven (7) years following each transaction, as required for financial compliance and audit purposes.
• KYC Verification Documents: Retained for the duration of your account plus five (5) years following closure, or longer if required by applicable law.
• Support Communications: Retained for three (3) years following the resolution of each support interaction, to allow for dispute review and quality assurance.
• Technical and Usage Data: Retained in aggregated, anonymised form for up to two (2) years for analytics purposes. Individually identifiable technical data is deleted within twelve (12) months of collection.
• Marketing Consent Records: Retained for the duration of the consent plus three (3) years, to demonstrate compliance with consent requirements.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with our internal data disposal procedures. Backups containing personal data are purged on a rolling schedule aligned with these retention periods.

Data Security

ld89 takes the security of your personal data seriously and implements a comprehensive range of technical and organisational measures to protect it against unauthorised access, accidental loss, alteration, or disclosure. Key security measures in place include:

• End-to-end 256-bit SSL/TLS encryption for all data transmitted between your device and the ld89 Platform.
• Encryption at rest for all stored personal data and financial records on our servers.
• Role-based access controls ensuring that staff can only access the data they need to perform their specific job functions.
• Multi-factor authentication required for all administrative and support staff who access Player account data.
• Regular penetration testing and independent security audits conducted by qualified third-party cybersecurity professionals.
• Intrusion detection and prevention systems monitoring for suspicious access patterns and potential data breaches in real time.
• Segregated network architecture isolating the Platform's payment processing environment from general application servers.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, ld89 will notify affected Players without undue delay and will take all reasonably practicable steps to contain and remediate the breach. ld89 maintains a documented incident response plan for this purpose.

Your Privacy Rights

As a registered Player and data subject, you hold the following rights with respect to your personal data held by ld89. To exercise any of these rights, please submit a written request to [email protected] with the subject line "Data Subject Request". We will acknowledge your request within five (5) business days and respond in full within thirty (30) calendar days.

• Right of Access: You have the right to request a copy of the personal data ld89 holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data held about you. Minor corrections (such as updating your contact number) can be made directly through your account settings.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to ld89's overriding legal obligations to retain certain records.
• Right to Restrict Processing: You have the right to request that ld89 restricts the processing of your personal data in certain circumstances, for example while a rectification request is being assessed.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, machine-readable format and to request that it be transferred to another service provider where technically feasible.
• Right to Object: You have the right to object to the processing of your personal data where ld89 relies on legitimate interests as the legal basis, including in the context of direct marketing.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing that took place prior to withdrawal.

Please note that some of these rights are not absolute and may be subject to limitations where ld89 has compelling overriding legal grounds for continued processing, particularly in relation to anti-money laundering compliance, responsible gaming obligations, and the resolution of ongoing disputes.

Children's Privacy

The ld89 Platform is strictly an adult service intended for individuals who are 21 years of age or older. We do not knowingly collect, process, or retain personal data from any individual under the age of 21. Registration by minors is explicitly prohibited under our Terms & Conditions.

If ld89 becomes aware that personal data has been collected from an individual under the age of 21 without appropriate age verification having been completed, we will immediately suspend the relevant account, delete the associated personal data to the extent permitted by law, and investigate how the minor was able to gain access to the Platform.

If you are a parent or guardian and believe that a minor in your care has registered on the ld89 Platform, please contact us immediately at [email protected] with the subject line "Underage Account". We will treat such reports as a priority and respond within 24 hours.

Marketing Communications

ld89 may send you promotional emails, SMS messages, and in-platform notifications about bonuses, new games, seasonal offers (such as Eid promotions or BPL betting specials), and other ld89 news — but only where you have provided your explicit consent to receive such communications during the registration process or through your account settings.

You may opt out of marketing communications at any time by:

• Clicking the "Unsubscribe" link included in any promotional email we send you.
• Adjusting your notification preferences in the Communications section of your ld89 account settings.
• Contacting our support team at [email protected] and requesting removal from all marketing lists.

Opting out of marketing communications will not affect the delivery of transactional communications that are necessary for the operation of your account, such as deposit confirmations, withdrawal notifications, account security alerts, and KYC status updates.

Third-Party Links

The ld89 Platform may contain references to third-party game providers, payment services, and other external services. Please note that ld89's Privacy Policy applies solely to data collected and processed by ld89 in connection with the operation of the Platform. It does not extend to the privacy practices of third-party providers whose services you access in connection with your use of the Platform.

We recommend reviewing the privacy policies of all third-party services you interact with, including your chosen mobile payment provider (bKash, Nagad, Rocket, or Upay), to understand how they collect and use your data independently of ld89.

Updates to This Privacy Policy

ld89 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, our data processing practices, or the services we provide. The most current version of this Policy will always be available on this page, along with the date it was last revised.

Where changes to this Privacy Policy are material — meaning they significantly affect your rights or the way in which we process your personal data — ld89 will notify registered Players via email and through a prominent in-platform notice at least fourteen (14) days prior to the changes taking effect, giving you the opportunity to review the updated Policy before it applies to you.

Your continued use of the Platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the changes, please contact us to close your account before the revised Policy takes effect.

Contact Us About Privacy

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way in which ld89 processes your personal data, please contact our dedicated privacy team using the details below. All enquiries must be submitted in English.

• Privacy Enquiries: [email protected] — subject line: "Privacy Enquiry"
• Data Subject Requests: [email protected] — subject line: "Data Subject Request"
• Underage Account Reports: [email protected] — subject line: "Underage Account"
• Response Time: Acknowledgement within 5 business days; full response within 30 calendar days
• Support Hours: 24 hours a day, 7 days a week

We take all privacy enquiries seriously and will investigate each complaint thoroughly. If you are not satisfied with our response, you may have the right to lodge a complaint with a relevant data protection authority or seek judicial remedy under applicable law.