89bd3 Privacy Policy — How We Collect, Use, and Protect Your Personal Data

89bd3 ("we", "us", "our", or "the Platform") is an offshore online betting and gaming platform serving English-speaking users across Bangladesh. We operate the website available at https://89bd3.io and all related subdomains, mobile-optimised pages, and associated services (collectively, "the Platform").

This Privacy Policy describes how 89bd3 collects, uses, stores, discloses, and otherwise processes personal data in connection with your use of the Platform. "Personal data" means any information that identifies or could reasonably identify you as an individual — including your name, email address, mobile number, payment details, device identifiers, and usage behaviour on the Platform.

89bd3 takes its data protection obligations seriously. We apply industry-standard security controls, limit data collection to what is genuinely necessary to deliver our services, and do not sell your personal data to third-party advertisers or data brokers under any circumstances.

If you have questions about this Privacy Policy or wish to exercise any of your data rights, please contact us at support@89bd3.io. Our English-language support team is available 6:00 AM to 2:00 AM Bangladesh Standard Time (BST, UTC+6), seven days a week including public holidays.

89bd3 collects the following categories of personal data from registered users and Platform visitors. We only collect data that is necessary for the specific purpose described alongside each category.

89bd3 does not intentionally collect sensitive personal data categories such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data beyond what is required for standard identity verification (e.g., a government-issued photo ID). If KYC verification requires document submission, the data is processed solely for identity verification and fraud prevention purposes and is not retained for any other purpose.

89bd3 collects personal data through the following channels and mechanisms:

• Direct submission: You provide data to us directly when you register an account, complete KYC verification, submit a deposit or withdrawal request, contact support via email, respond to a survey, or update your account profile settings.
• Automated collection: When you access the Platform, our servers automatically record technical data such as your IP address, device identifiers, and session duration. This occurs whether or not you are logged in and applies to all Platform visitors.
• Payment processors: When you conduct a financial transaction using bKash, Nagad, Rocket, Upay, or a Bangladeshi banking partner, the payment processor confirms transaction details (amount, timestamp, wallet/account reference) to 89bd3 for the purposes of crediting your account balance and maintaining transaction records.
• Game providers: Licensed third-party game studios (including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi) may return game outcome and session data to 89bd3 for the purposes of account balance updates, dispute resolution, and responsible gaming monitoring.
• Cookies and tracking technologies: 89bd3 uses first-party cookies and similar technologies to maintain your login session, remember preferences, and collect aggregate analytics data. See Section 9 for full details of our cookie practices.
• Identity verification partners: Where automated KYC verification is used, a certified identity verification provider may process your submitted documents and return a verification result (pass/fail) to 89bd3. The third-party provider operates under its own privacy policy and data processing agreement with 89bd3.

89bd3 processes your personal data for the following specific, legitimate purposes. We do not use your data for any purpose that is incompatible with those listed below without first seeking your explicit consent.

• Account registration and management: To create, maintain, and secure your 89bd3 account, verify your identity, process password resets, and communicate account-related notifications.
• Service delivery: To process bets, settle game outcomes, credit winnings, apply bonuses, and deliver the core betting and gaming experience on the Platform.
• Payment processing: To initiate and verify deposits and withdrawals via bKash, Nagad, Rocket, Upay, and Bangladeshi bank transfer partners, reconcile transaction records, and detect payment anomalies.
• Identity and age verification: To confirm that you meet the 21+ minimum age requirement and to verify that account information is accurate and not fraudulent, in compliance with our Know Your Customer obligations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent account activity, money laundering, bonus abuse, multi-accounting, and other prohibited conduct described in the Terms & Conditions.
• Responsible gaming compliance: To monitor usage patterns that may indicate problem gambling behaviour, enforce self-exclusion periods and deposit limits, and respond to responsible gaming requests from users or their authorised representatives.
• Legal and regulatory compliance: To maintain records required under applicable anti-money-laundering and counter-terrorism-financing obligations, respond to lawful requests from competent authorities, and meet our obligations under the Platform's offshore operating licence.
• Customer support: To respond to your support queries, investigate complaints, and maintain a record of communications for quality assurance and dispute resolution purposes.
• Platform improvement: To analyse aggregate usage patterns, identify technical issues, test new features, and improve the overall Platform experience. Analytics data used for this purpose is aggregated and de-identified wherever possible.
• Marketing and promotions: To send you promotional offers, bonus notifications, and event announcements where you have opted in to receive such communications. You may withdraw consent for marketing communications at any time via your account settings or by emailing support@89bd3.io.

89bd3 processes your personal data on one or more of the following legal bases, depending on the specific purpose and context of the processing:

• Contractual necessity: Processing that is necessary to perform the contract between you and 89bd3 — specifically, to deliver the betting and gaming services you have registered for, process your financial transactions, and manage your account.
• Compliance with a legal obligation: Processing required to meet our obligations under applicable anti-money-laundering laws, Know Your Customer regulations, and any lawful order or request from a competent authority.
• Legitimate interests: Processing that is necessary for 89bd3's legitimate business interests — such as fraud prevention, security monitoring, service improvement, and responsible gaming oversight — provided that those interests are not overridden by your privacy rights.
• Consent: Processing that is based on your freely given, specific, and informed consent — in particular, the sending of direct marketing communications and the use of non-essential tracking cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

89bd3 does not sell, rent, or trade your personal data to any third party. We share your data only in the specific circumstances described below, and only to the extent strictly necessary for each purpose.

• Payment processors: Transaction data (including your bKash, Nagad, Rocket, or Upay wallet reference and transaction amount) is shared with our payment processing partners solely to facilitate the deposit or withdrawal you have requested. Payment processors operate under their own privacy frameworks and are bound by data processing agreements with 89bd3.
• Identity verification providers: Identity documents submitted for KYC verification are shared with our certified verification partner for the sole purpose of confirming your identity and age. Verification results are returned to 89bd3; the underlying documents are handled in accordance with the verification partner's data retention policies as described in their privacy notice.
• Game providers: Session identifiers and minimum necessary account data are shared with our licensed game studio partners (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and others) to facilitate game delivery, outcome settlement, and responsible gaming controls within their game environments.
• Fraud and security vendors: Anonymised or pseudonymised technical data (such as device fingerprints and IP addresses) may be processed by our fraud detection service providers to identify suspicious patterns. These vendors act as data processors under contract with 89bd3 and may not use this data for their own purposes.
• Legal authorities: 89bd3 may disclose personal data to law enforcement agencies, financial intelligence units, courts, or other public authorities where we are legally required to do so, or where disclosure is necessary to protect the safety of our users or the integrity of the Platform. We will not disclose data in response to informal or legally unsupported requests.
• Business transfers: In the event of a merger, acquisition, restructuring, or sale of all or part of 89bd3's business assets, user data may be transferred to the acquiring or succeeding entity as part of that transaction. We will notify registered users via their registered email address if such a transfer materially affects how their data is processed.

All third parties with whom 89bd3 shares personal data are required to handle that data securely, to use it only for the purposes for which it was shared, and to comply with applicable data protection standards. We do not permit our data processors to sub-process personal data without our prior written consent.

89bd3 retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable legal, regulatory, or operational obligations. The following indicative retention periods apply:

When data is no longer required under the periods above, 89bd3 will securely delete or anonymise it so that it can no longer be associated with any individual user. Where deletion is not immediately technically feasible (for example, data held in encrypted backup archives), the data will be isolated from active processing and deleted at the earliest practicable opportunity.

If you request account closure, 89bd3 will deactivate your account promptly. However, certain data categories — particularly financial transaction records and KYC documents — will be retained for the periods specified above to meet our legal obligations, even after your account is closed.

89bd3 implements a multi-layered approach to data security, combining technical, organisational, and procedural safeguards to protect your personal data against unauthorised access, disclosure, alteration, or destruction. The following measures are in place across all aspects of the Platform:

• Encryption in transit: All data transmitted between your browser or device and 89bd3's servers is encrypted using TLS 1.2 or higher (256-bit SSL encryption). This applies to all pages of the Platform, including registration, login, deposit, and withdrawal flows.
• Encryption at rest: Sensitive data fields — including passwords (stored as one-way hashed values), payment account references, and identity document images — are encrypted at rest using AES-256 or equivalent standards.
• Access controls: Access to personal data within 89bd3's internal systems is restricted on a strict need-to-know basis. Staff who handle personal data are subject to confidentiality obligations and receive data protection training appropriate to their role.
• Multi-factor authentication: Administrative access to production systems and databases requires multi-factor authentication. 89bd3 also provides optional two-factor authentication for user accounts to add an additional layer of login security.
• Intrusion detection and monitoring: 89bd3 operates continuous server-side monitoring and intrusion detection systems. Anomalous activity patterns — including unusual login attempts, bulk data access, and payment irregularities — trigger automated alerts for investigation.
• Third-party security audits: 89bd3 engages independent technical assessors to conduct periodic security reviews and penetration testing of the Platform's infrastructure and application layer.
• Data breach response: In the event of a personal data breach that is likely to result in a risk to affected individuals, 89bd3 will notify affected users at their registered email address without undue delay, describing the nature of the breach, the data affected, and the steps being taken to address it.

While 89bd3 takes all reasonable and practicable steps to secure your personal data, no internet-based system can offer absolute security guarantees. You are responsible for maintaining the security of your account credentials and for notifying 89bd3 promptly if you suspect any unauthorised access to your account.

89bd3 uses cookies and similar client-side storage technologies to operate the Platform effectively and to understand how it is used. A cookie is a small text file placed on your device by a web server when you access a website. Cookies do not execute programs or carry viruses.

89bd3 uses the following categories of cookies:

• Strictly necessary cookies: These cookies are essential for the Platform to function. They maintain your login session after you authenticate, remember your language preference, and prevent cross-site request forgery attacks. These cookies cannot be disabled without breaking core Platform functionality. No consent is required for strictly necessary cookies.
• Functional cookies: These cookies remember choices you have made — such as your preferred payment method, display settings, or responsible gaming limits — so that you do not need to re-enter them on each visit. These cookies improve convenience but are not essential to the Platform's core operation.
• Analytics cookies: These cookies collect aggregate, pseudonymised data about how users navigate the Platform — for example, which pages are visited most frequently, how long sessions last, and where users exit the Platform. This data is used to improve Platform design and content. Analytics data is not linked to your individual identity.
• Marketing cookies: Where you have consented to receiving personalised promotional communications, 89bd3 may use cookies to record which promotions you have viewed or interacted with, enabling us to avoid sending you duplicate offers and to tailor future promotions to your interests. You may withdraw consent for marketing cookies at any time via your account settings.

89bd3 does not use third-party advertising cookies or permit advertising networks to place tracking cookies on the Platform. The cookies used on 89bd3 are either first-party (set by 89bd3 directly) or set by essential service providers such as our analytics platform or payment processor integration, and are bound by data processing agreements.

You may control cookies through your browser settings. Most modern browsers allow you to view, block, or delete cookies at a granular level. Please be aware that blocking strictly necessary cookies will prevent you from logging in and using core Platform features.

89bd3 respects your rights as a data subject. Depending on your jurisdiction and the applicable legal framework, you may have the following rights in relation to the personal data we hold about you:

• Right of access: You have the right to request a copy of the personal data that 89bd3 holds about you, along with information about how it is being used. 89bd3 will respond to verified access requests within 30 days of receipt.
• Right to rectification: If any personal data held by 89bd3 is inaccurate or incomplete, you have the right to request that it be corrected. You may update many account details directly via your account profile settings. For data that cannot be self-corrected, contact support@89bd3.io.
• Right to erasure: You may request that 89bd3 delete your personal data where it is no longer necessary for the purpose for which it was collected, or where you withdraw consent and there is no other legal basis for continued processing. Please note that this right is subject to our legal retention obligations — financial transaction records, for example, must be retained for regulatory purposes even after an account is closed.
• Right to restriction of processing: You may request that 89bd3 restrict the processing of your personal data in certain circumstances — for example, while a dispute about the accuracy of your data is being investigated, or where you have objected to processing based on legitimate interests and we are assessing that objection.
• Right to data portability: Where processing is based on your consent or on contractual necessity and is carried out by automated means, you have the right to receive a copy of your personal data in a structured, commonly used, machine-readable format, and to request that this data be transmitted to another service provider where technically feasible.
• Right to object: You have the right to object at any time to the processing of your personal data on the basis of legitimate interests, including profiling carried out on that basis. Where you object, 89bd3 will cease processing unless we can demonstrate compelling legitimate grounds that override your rights, or where processing is necessary for the establishment, exercise, or defence of legal claims.
• Right to withdraw consent: Where processing is based on your consent — in particular, for marketing communications and non-essential cookies — you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

The 89bd3 Platform is strictly intended for adults aged 21 and above. 89bd3 does not knowingly collect personal data from any person under the age of 21. The Platform's registration process requires users to confirm their date of birth and to declare that they meet the minimum age requirement. Age verification checks are conducted as part of the KYC process, and accounts found to belong to individuals under 21 will be immediately terminated.

If 89bd3 becomes aware that personal data has been collected from a person under the age of 21 — whether through a failed age verification check, a complaint from a parent or guardian, or any other means — that data will be deleted without delay, any associated account will be permanently closed, and any funds held in the account will be returned to the originating payment method after applicable fraud checks.

If you are a parent or guardian and believe that your child under the age of 21 has registered on the 89bd3 Platform, please contact us immediately at support@89bd3.io with the subject line "Underage Account Report". We will investigate and act on all such reports as a priority matter. 89bd3 encourages parents and guardians to use parental control software to restrict access to gambling websites on shared or family devices.

89bd3 operates as an offshore platform and its primary servers and data infrastructure are located outside Bangladesh. As a result, the personal data you provide to 89bd3 may be transferred to, stored in, and processed in jurisdictions outside Bangladesh, including the offshore jurisdiction where 89bd3 is incorporated and operates.

When personal data is transferred to a third-party service provider located in another country — for example, a certified KYC verification provider or a game studio analytics system — 89bd3 ensures that appropriate safeguards are in place to protect that data. These safeguards may include contractual clauses that impose equivalent data protection obligations on the receiving party, or reliance on the data protection framework of the receiving jurisdiction where it provides adequate protections.

By registering an account on 89bd3 and accepting this Privacy Policy, you acknowledge and consent to the international transfer of your personal data as described in this section. If you do not agree to such transfers, you should not register for or use the Platform.

89bd3's payment processing partners — bKash, Nagad, Rocket, and Upay — are Bangladeshi-based entities that process local transaction data within Bangladesh's domestic financial infrastructure. Data shared with these partners for the purpose of payment processing is governed by their respective privacy notices and applicable Bangladeshi financial regulations.

89bd3 reserves the right to amend, update, or replace this Privacy Policy at any time. When material changes are made — such as changes to the categories of data collected, the purposes for which it is used, the third parties with whom it is shared, or your data rights — 89bd3 will post a prominent notice on the Platform and update the "Effective Date" shown at the top of this document.

Where changes are particularly significant, 89bd3 may also send a notification to your registered email address. Your continued use of the Platform after the updated Privacy Policy has been posted constitutes your acceptance of the revised terms. If you do not agree with any update to this Privacy Policy, you must stop using the Platform and may request account closure as described in the Terms & Conditions.

89bd3 recommends that you review this Privacy Policy periodically to stay informed of how we are protecting your data. The current version of the Privacy Policy is always accessible at https://89bd3.io/privacy-policy and is identified by its version number and effective date.

If you have any questions, concerns, or complaints regarding this Privacy Policy, the way 89bd3 handles your personal data, or if you wish to exercise any of your data rights as described in Section 10, please contact our support team using the details below. All data-related correspondence must be submitted in English.

89bd3 does not accept privacy complaints or data rights requests submitted via social media channels. To ensure your request is handled formally and with a proper audit trail, all submissions must be made in writing via email to support@89bd3.io.

89bd3 is committed to resolving all privacy-related concerns promptly and transparently. If you are not satisfied with our response to a data rights request or privacy complaint, you may escalate your concern by submitting a follow-up email marked "Escalation" to support@89bd3.io, and your case will be reviewed by a senior member of our compliance team.