Privacy Policy — How le89 Protects Your Data

1 Introduction

This Privacy Policy ("Policy") describes how le89 ("the Platform", "we", "us", "our") collects, processes, stores, shares, and protects personal data belonging to individuals ("you", "your", "the Player") who visit, register on, or use the le89 online betting and gaming platform available at le89.io.

le89 operates as an online betting and gaming platform serving the Bangladesh market, offering sports wagering, live casino games, slots, crash games, and related services. In providing these services, le89 necessarily processes certain personal data about players and prospective players. We take our obligations as a data controller seriously and are committed to handling your information fairly, transparently, and securely.

This Policy applies to all personal data collected through the le89 website, mobile interface, customer support channels, promotional communications, and any other digital touchpoint associated with the le89 brand. It does not apply to third-party websites or services that may be linked from our platform — those are governed by their own privacy policies.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, which together form the complete agreement between you and le89 governing your use of the platform.

2 Personal Data We Collect

le89 collects personal data through several channels. The categories of data we collect are described below.

2.1 Registration Data

When you create an account on le89, we collect the information you provide during the registration process, including:

• Full legal name
• Date of birth (used for age verification — players must be 21 or older)
• Residential address, including district and division within Bangladesh
• Mobile phone number (used for account verification and security alerts)
• Email address
• Chosen username and encrypted password

2.2 Identity Verification (KYC) Data

As part of our Know Your Customer (KYC) obligations, we may collect copies of documents including:

• National Identity Card (NID)
• Passport biographical page
• Driving licence
• Utility bills or bank statements as proof of address (dated within three months)
• Proof of ownership of the payment method used (e.g., screenshot of bKash or Nagad account registered in your name)

2.3 Financial Transaction Data

We record all financial activity on your account, including deposit amounts and timestamps, withdrawal requests and processing status, payment method identifiers (mobile number associated with bKash, Nagad, Rocket, or Upay accounts — we do not store full card numbers), bonus credits applied, and account balance history. This data is retained for compliance, fraud prevention, and dispute resolution purposes.

2.4 Betting and Gaming Activity Data

We log all wagering activity on the platform, including sports bets placed (market, selection, odds, stake, outcome), casino game sessions (game name, provider, session duration, round results), crash game rounds (Aviator by Spribe and similar titles), and cumulative win/loss records. This data is used to operate the service, detect problem gambling patterns, and investigate disputes.

2.5 Technical and Device Data

When you access le89, our systems automatically collect certain technical information, including:

• IP address and approximate geographic location derived from IP
• Device type, operating system, and browser version
• Unique device identifiers
• Session timestamps and duration
• Pages visited and navigation path within the platform
• Referring URL (if you arrived via a link from another site)

2.6 Communications Data

If you contact our support team via email or live chat, we retain a record of the communication, including the date, content, and resolution outcome. This data is used for quality assurance, staff training, and to maintain a history of your support interactions.

2.7 Marketing Preferences

Where you have opted in to receive promotional communications from le89, we record that preference along with your communication history (emails sent, opened, and clicked). You may withdraw marketing consent at any time by contacting [email protected] or using the unsubscribe mechanism included in any marketing email.

3 How We Use Your Personal Data

le89 uses the personal data it collects for the following specific purposes:

le89 does not use your personal data for automated decision-making that produces legal or similarly significant effects without a human review stage. If any profiling activity is introduced in future, it will be disclosed in an updated version of this Policy.

4 Legal Bases for Processing

le89 processes your personal data on the following legal bases:

• Contractual necessity: Processing your registration data, KYC documents, financial transaction records, and gaming activity data is necessary to perform the contract between you and le89 (i.e., to operate your account and provide the betting and gaming service you have signed up for).
• Legal obligation: Processing for KYC, anti-money laundering (AML) checks, fraud reporting, and record retention is necessary to comply with applicable laws and regulations.
• Legitimate interests: Processing technical data, security logs, and communications data is carried out in le89's legitimate interests of maintaining platform security, preventing fraud, improving services, and protecting the rights of other players. We have assessed that these interests are not overridden by your privacy rights.
• Consent: Processing your data for marketing communications and certain optional personalisation features is based on your explicit consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out before withdrawal.

5 Cookies and Tracking Technologies

5.1 What Are Cookies

Cookies are small text files placed on your device when you visit le89. They allow the platform to recognise your device on subsequent visits, remember your session preferences, and collect statistical data about how the platform is used. le89 also uses similar technologies such as pixel tags and local storage in limited circumstances.

5.2 Types of Cookies Used

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without breaking core platform functionality.
• Functional Cookies: Remember your preferences such as language settings, odds format selection, and notification preferences. Disabling these will not prevent you from using the platform but will reset your preferences on each visit.
• Analytics Cookies: Collect anonymised statistical data about how players navigate the platform — which pages are visited most, how long sessions last, and where users encounter errors. This data helps le89 improve the platform experience.
• Security and Fraud Prevention Cookies: Used to detect suspicious behaviour, prevent account takeover attacks, and identify devices associated with prior fraudulent activity.

5.3 Managing Cookies

You may manage cookie preferences through your browser settings. Most modern browsers allow you to block or delete cookies at the category or individual level. Please note that disabling strictly necessary cookies will prevent you from logging in or using key platform features. Detailed instructions for managing cookies in common browsers are available from the browser's official support documentation.

6 Sharing Your Personal Data

le89 does not sell your personal data. We share data with third parties only in the following limited circumstances:

• Payment processors: Your financial transaction data is shared with bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, City Bank, and Islami Bank solely for the purpose of processing deposits and withdrawals. Each processor operates under its own privacy and data security standards.
• Game content providers: When you play a game hosted by a third-party provider (such as Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, or Ezugi), your session data and game results are processed by that provider's servers. These providers are contractually bound to maintain data confidentiality and to use your data only for game delivery and integrity purposes.
• KYC and identity verification services: We may use third-party identity verification providers to assist with document authentication and age verification. These providers process the KYC documents you submit solely for verification purposes and do not retain them beyond the verification period.
• Fraud prevention and AML services: We share data with specialist third-party fraud detection platforms and AML screening services as part of our obligation to maintain a safe and compliant platform.
• Legal and regulatory authorities: We may disclose personal data to law enforcement agencies, regulatory bodies, or courts where we are legally required to do so, or where disclosure is necessary to protect the rights and safety of le89, its players, or the general public.
• Professional advisers: Our legal counsel, auditors, and insurers may access personal data on a need-to-know basis in the course of providing professional services to le89. All such parties are bound by confidentiality obligations.

Any third party that receives personal data from le89 is required to process that data solely for the purpose for which it was shared and to maintain appropriate technical and organisational security measures.

7 International Data Transfers

le89 primarily serves players based in Bangladesh. However, some of our third-party service providers — including game content delivery networks, cloud infrastructure providers, and fraud prevention services — may process data on servers located outside Bangladesh.

Where personal data is transferred outside Bangladesh, le89 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to, or higher than, that required under applicable data protection principles. Safeguards include contractual data processing agreements with the receiving party that incorporate standard data protection clauses.

If you would like further information about the specific safeguards applied to any international transfer of your data, please contact our support team at [email protected].

8 Data Retention

le89 retains personal data for different periods depending on the category of data and the purpose for which it is held:

Once the applicable retention period has expired, personal data is securely deleted or anonymised so that it can no longer be associated with you as an individual.

9 Your Privacy Rights

As a player on le89, you hold the following rights in relation to your personal data. To exercise any of these rights, please contact our support team at [email protected] with the subject line "Privacy Rights Request":

• Right of Access: You may request a copy of the personal data le89 holds about you. We will provide a structured summary of your data within a reasonable timeframe, typically within 30 days of a verified request.
• Right to Rectification: If any of the personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. For account details such as your registered address or phone number, you may update these directly through your account profile.
• Right to Erasure: You may request that le89 delete the personal data we hold about you. This right is subject to limitations — le89 is required to retain certain data for legal, regulatory, and fraud prevention purposes even after account closure. We will inform you of what data can and cannot be deleted when processing your request.
• Right to Restrict Processing: In certain circumstances, you may request that le89 restrict the processing of your data — for example, if you contest the accuracy of the data we hold, or if you believe our processing is unlawful but you do not wish for the data to be deleted.
• Right to Data Portability: You may request a copy of the personal data you have provided to le89 in a structured, machine-readable format (such as JSON or CSV), where technically feasible.
• Right to Object: You have the right to object to processing of your personal data where that processing is based on le89's legitimate interests. If you object, we will assess whether our legitimate interests override your privacy rights in the specific circumstances.
• Right to Withdraw Consent: Where processing is based on your consent (such as marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of any processing carried out prior to withdrawal.

le89 will respond to all verified privacy rights requests within 30 days. In complex cases, we may extend this period by a further 60 days, in which case we will notify you of the extension and the reason for the delay. We reserve the right to charge a reasonable administrative fee for manifestly unfounded or repetitive requests.

10 Children's Privacy

le89 is strictly an adult platform. The Service is intended only for individuals who are aged 21 years or older. le89 does not knowingly collect personal data from anyone under the age of 21.

Age verification is conducted as a mandatory step in the account registration and KYC process. If le89 discovers or reasonably suspects that a registered account belongs to a person under the age of 21, the account will be immediately suspended, all wagering activity will be voided, and any deposits will be returned to the source payment method after investigation.

If you believe that a minor has registered on the le89 platform, please contact us immediately at [email protected]. We take underage gambling extremely seriously and will act on any credible report without delay. For guidance on protecting minors from gambling-related content, please visit our Responsible Gaming page.

11 Security Measures

le89 implements a layered security architecture to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. Our security measures include, but are not limited to:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and le89 servers is encrypted in transit using industry-standard TLS protocols.
• Encrypted Data Storage: Sensitive personal data, including password hashes and KYC document references, is stored using strong cryptographic encryption at rest.
• Access Controls: Access to player personal data within le89's internal systems is restricted on a strict need-to-know basis. Staff with data access privileges are subject to background checks, confidentiality agreements, and regular security training.
• Two-Factor Authentication: Players are encouraged to enable two-factor authentication (2FA) on their accounts. le89 staff accounts with access to player data require mandatory 2FA.
• Real-Time Fraud Monitoring: Automated systems continuously monitor account activity for patterns consistent with fraud, account takeover, or unusual financial behaviour. Suspicious activity triggers immediate review by our security team.
• Regular Security Auditing: le89's infrastructure and application layer undergo periodic security assessments, including vulnerability scanning and penetration testing, conducted by qualified security professionals.
• Incident Response: le89 maintains a data breach incident response plan. In the event of a breach that poses a risk to your personal data, affected players will be notified promptly with details of the incident and the steps being taken to contain it.

While le89 applies rigorous security standards, no online platform can guarantee absolute security against all threats. Players are encouraged to use strong, unique passwords for their le89 account, enable 2FA, and report any suspicious account activity to [email protected] immediately.

12 Third-Party Links and Integrations

The le89 platform may contain references to or integrations with third-party game providers, payment processors, and service partners. Where game content is delivered by providers such as Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, or Ezugi, those providers' platforms handle certain session-level data independently.

le89 is not responsible for the privacy practices of third-party providers. Players are encouraged to review the privacy policies of any third-party service they interact with. le89 conducts due diligence on all third-party partners before integrating their services, and requires that all partners maintain data protection standards consistent with le89's own policies through contractual data processing agreements.

13 Changes to This Privacy Policy

le89 reserves the right to update or revise this Privacy Policy at any time. Where changes are material — meaning they substantially affect how your data is collected, used, or shared — le89 will provide advance notice via email to your registered address or via a prominent notification within your account, no less than seven (7) days before the updated policy takes effect.

Non-material changes, such as typographical corrections or clarifications that do not alter the substance of any provision, may be made without prior notice. The effective date displayed at the top of this Policy will be updated with each revision. We encourage you to review this Policy periodically to remain informed of how your data is being protected.

If you disagree with any change to this Privacy Policy, you have the right to close your account before the revised policy takes effect. Continued use of the le89 platform after the effective date of a revised policy constitutes your acceptance of the updated terms.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way le89 handles your personal data, please contact our dedicated support team using the details below. All privacy-related enquiries are handled in English by trained agents available 24 hours a day, 7 days a week, including Bangladesh public holidays.