89bd Privacy
Policy

1 Introduction

This Privacy Policy describes how 89bd ("89bd", "we", "us", "our"), operating the online platform at https://89bd.bar (the "Platform"), collects, uses, stores, and protects personal data relating to registered players, prospective users, and visitors to the Platform (collectively, "you", "your").

By accessing or using the 89bd Platform, creating an account, making a deposit, placing a wager, or contacting our support team, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein. If you do not agree with any aspect of this Privacy Policy, please discontinue your use of the Platform immediately.

This Privacy Policy should be read alongside the 89bd Terms and Conditions, which govern the overall relationship between you and 89bd. Where the Terms and Conditions contain provisions that relate to data handling, this Privacy Policy provides the controlling detail for those provisions.

2 Data We Collect

89bd collects the following categories of personal data in connection with your use of the Platform:

89bd does not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data (other than responsible gaming self-assessments), or biometric data beyond what is required for standard identity document verification.

3 How We Collect Data

89bd collects personal data through the following means:

• Direct interactions: Data you provide when you register an account, complete KYC, make a deposit or withdrawal, contact support, or respond to a survey or promotion.
• Automated technologies: When you access the Platform, our servers automatically log technical data including your IP address, device fingerprint, browser type, and session duration. This data is captured via server logs, cookies, and similar technologies described in Section 9.
• Third-party payment providers: When you transact via bKash, Nagad, Rocket, Upay, or a Bangladeshi bank, the payment provider may share transaction confirmation data with 89bd for the purpose of crediting your account and verifying payment integrity.
• Identity verification partners: 89bd may use third-party KYC and anti-money-laundering service providers to verify the authenticity of identity documents you submit. These providers process your data solely on 89bd's instructions and are bound by strict confidentiality obligations.
• Publicly available sources: In limited circumstances related to fraud prevention, 89bd may cross-reference data against publicly available databases such as sanctions lists or politically exposed persons (PEP) registers.

4 Purposes of Processing

89bd processes your personal data for the following specific purposes:

• Account creation and management: To register your account, verify your identity, maintain your player profile, and provide access to the Platform's features.
• Payment processing: To process deposits and withdrawals via supported Bangladeshi payment methods, reconcile transactions, and detect payment fraud.
• Legal and regulatory compliance: To meet obligations under applicable anti-money-laundering (AML) frameworks, know-your-customer (KYC) requirements, and to respond to lawful requests from competent authorities.
• Responsible gaming: To monitor usage patterns for indicators of problem gambling, apply player-requested limits and self-exclusion restrictions, and maintain associated audit records.
• Platform security and fraud prevention: To detect and prevent unauthorised access, account takeovers, bonus abuse, collusion, and other fraudulent or prohibited activities.
• Customer support: To respond to your enquiries, resolve disputes, and maintain records of communications for quality assurance purposes.
• Service improvement and analytics: To analyse aggregate and anonymised usage data to improve Platform performance, game offerings, and the overall user experience.
• Marketing communications: To send you promotional offers, bonus notifications, and platform news where you have consented to receive such communications. You may withdraw this consent at any time by contacting support.

5 Legal Basis for Processing

89bd processes personal data on the following legal bases, depending on the purpose of processing:

• Contractual necessity: Processing required to perform the contract between you and 89bd — principally, maintaining your account, processing payments, and delivering the gaming and betting services you have requested.
• Legal obligation: Processing required to comply with applicable anti-money-laundering laws, KYC requirements, sanctions screening obligations, and any lawful order from a competent governmental or judicial authority.
• Legitimate interests: Processing carried out to pursue 89bd's legitimate business interests in preventing fraud, ensuring Platform security, improving services, and managing responsible gaming obligations — provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications and for optional analytics beyond what is strictly necessary for Platform operation. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

6 Data Sharing and Disclosure

89bd does not sell your personal data. We may share your data with the following categories of recipients only to the extent strictly necessary:

• Payment service providers: bKash, Nagad, Rocket, Upay, and partnered Bangladeshi banks, solely for the purpose of processing your deposits and withdrawals. These providers act as independent data controllers for their own services and are subject to their own privacy policies.
• KYC and AML service providers: Third-party identity verification and anti-money-laundering screening partners who process identity document data on 89bd's instructions under data processing agreements that bind them to confidentiality and security standards equivalent to those in this Policy.
• Game content providers: Licensed game developers — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi — may receive anonymised session and technical data necessary to deliver their games. These providers do not receive your identity or financial data unless required for jackpot verification under their own regulatory obligations.
• IT and hosting infrastructure providers: Cloud hosting, content delivery, and cybersecurity service providers who process technical data on 89bd's behalf under contractual confidentiality obligations.
• Legal and regulatory authorities: Competent law enforcement bodies, financial intelligence units, or courts, where disclosure is required by a binding legal obligation or valid judicial order. 89bd will not disclose more data than the minimum required to satisfy such a request.

7 Data Retention

89bd retains personal data for the minimum period necessary to fulfil each processing purpose, subject to any longer period required by law. The following indicative retention periods apply:

• Account and identity data: Retained for the duration of your active account relationship with 89bd, and for a minimum of five (5) years following permanent account closure — in accordance with standard financial record-keeping and AML obligations applicable to offshore gaming operators.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by anti-money-laundering compliance frameworks.
• Support communications: Retained for three (3) years from the date of the most recent communication in a given support case, for quality assurance and dispute resolution purposes.
• Technical and usage logs: Retained for up to twelve (12) months from collection, after which they are anonymised or deleted.
• Marketing consent records: Retained until you withdraw consent plus an additional period of two (2) years to demonstrate compliance with consent management obligations.

When a retention period expires, 89bd will securely delete or irreversibly anonymise the relevant data so that it can no longer be associated with an identifiable individual.

8 Data Security

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

• Transport encryption: All data in transit between your device and 89bd's servers is protected using 256-bit SSL/TLS encryption. Our SSL certificate status is continuously monitored.
• At-rest encryption: Sensitive data fields — including identity document scans, financial account identifiers, and password hashes — are encrypted in storage using industry-standard algorithms.
• Access controls: Access to personal data within 89bd's systems is restricted on a strict need-to-know basis. Staff with authorised access are bound by confidentiality obligations and undergo regular security awareness training.
• Intrusion detection: 89bd's infrastructure is monitored around the clock by automated intrusion detection systems. Anomalous access patterns trigger immediate security review protocols.
• Password security: Passwords are never stored in plain text. 89bd uses one-way cryptographic hashing with salt to store password credentials, ensuring that even in the event of a data breach, raw passwords cannot be recovered.

While 89bd employs all reasonable security measures, no data transmission over the internet or electronic storage system is completely immune to risk. In the event of a data breach that is likely to result in a risk to your rights and freedoms, 89bd will notify affected players without undue delay.

9 Cookies and Tracking Technologies

89bd uses cookies and similar technologies — including local storage objects and session tokens — to operate and improve the Platform. A cookie is a small text file placed on your device when you visit a website. The following types of cookies are used on 89bd:

• Strictly necessary cookies: Essential for Platform functionality. They maintain your authenticated session, remember your language or currency preference, and ensure that security tokens function correctly. These cookies cannot be disabled without preventing core Platform features from working.
• Performance cookies: Used to collect anonymised and aggregated data about how visitors interact with the Platform — such as which game categories are most visited and where error pages are encountered. This data is used solely to improve Platform performance and is never linked to your individual identity.
• Functional cookies: Remember choices you have made on the Platform (such as your preferred game layout or notification settings) to provide a more personalised and consistent experience across sessions.

89bd does not use advertising cookies, cross-site tracking pixels, or third-party social media tracking scripts that would allow external parties to build a profile of your browsing behaviour across other websites.

You may control cookie behaviour through your browser's settings. Blocking strictly necessary cookies will affect Platform functionality. Disabling performance or functional cookies will not prevent you from using the Platform but may reduce the quality of your experience.

10 Your Privacy Rights

As a data subject, you hold the following rights in relation to the personal data that 89bd processes about you. To exercise any of these rights, contact our support team at support@89bd.bar or via live chat:

• Right of access: You may request a copy of the personal data 89bd holds about you, along with information about the purposes for which it is processed and the recipients to whom it has been disclosed.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data. For account-level data such as your name or contact details, you can update many fields directly within your account settings.
• Right to erasure: In certain circumstances, you may request that 89bd delete your personal data. This right is subject to exceptions where retention is required by law (for example, AML record-keeping obligations) or is necessary to establish, exercise, or defend a legal claim.
• Right to restriction: You may request that 89bd restrict processing of your personal data in defined circumstances, such as while the accuracy of the data is being contested.
• Right to data portability: You may request that 89bd provide your personal data in a structured, commonly used, machine-readable format where processing is based on consent or contractual necessity.
• Right to withdraw consent: Where processing is based on your consent — for example, marketing communications — you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
• Right to object: You may object to processing carried out on the basis of 89bd's legitimate interests where you have grounds relating to your particular situation. You have an absolute right to object to direct marketing processing at any time.

89bd will respond to all valid privacy rights requests within thirty (30) days of receipt. Where a request is complex or voluminous, 89bd may extend this period by a further sixty (60) days, with notice provided within the initial thirty-day window.

11 Children and Minors

The 89bd Platform is strictly intended for adults. Access to and use of the Platform is prohibited for any person under the age of 21. 89bd does not knowingly collect personal data from individuals under 21 years of age.

If 89bd becomes aware that personal data has been collected from a person under the age of 21, all such data will be permanently deleted and the associated account will be closed immediately, with any deposited funds returned through the original payment method after appropriate verification.

12 Changes to This Policy

89bd reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, applicable legal requirements, or the services we offer. The effective date shown at the head of this document will be updated each time a revision is made.

Where changes are material — meaning they substantially affect your rights or the way your personal data is processed — 89bd will notify you via the email address registered to your account at least seven (7) days before the revised policy takes effect. For non-material changes such as typographical corrections or clarifications that do not alter substantive rights, the updated policy will be published at 89bd.bar/privacy-policy and take effect immediately upon publication.

Continued use of the Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the changes. If you do not accept a revised policy, please close your account and cease use of the Platform before the effective date.

13 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 89bd processes your personal data, please reach out through the following channels:

• Email: support@89bd.bar (plain text — not a clickable link)
• Live Chat: Available 24 hours a day, 7 days a week, directly within the 89bd Platform
• Response Time: All privacy-related enquiries are acknowledged within 24 hours and resolved within 30 days, in accordance with Bangladesh Standard Time (BST, UTC+6)

When submitting a privacy rights request by email, please include your registered account username and a brief description of your request so that our team can locate your records efficiently. For identity verification purposes, 89bd may ask you to confirm certain account details before actioning a request that would result in disclosure, modification, or deletion of personal data.