2l89 Privacy Policy

Your Privacy at a Glance

1. Introduction

This Privacy Policy ("Policy") describes how 2l89 ("we", "us", "our") collects, uses, stores, discloses and protects personal information relating to users ("you", "your") of the 2l89 online casino and sports betting platform accessible at 2l89.app ("the Platform"). By registering an account or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and use of your information as described herein.

This Policy applies to all information collected through the Platform, including information provided during account registration, payment transactions, gameplay, and any communications with the 2l89 support team. It should be read alongside our Terms and Conditions, which govern your general use of the Platform.

2. Information We Collect

2l89 collects only the personal information necessary to provide a secure, compliant and functional online gaming experience. The categories of personal information we collect are listed below.

• ▸Identity information — full name, date of birth and government-issued photo identification (National ID or passport) collected for KYC verification before your first withdrawal.
• ▸Contact information — mobile number used for registration, OTP verification and support communications. An email address may also be collected where voluntarily provided.
• ▸Financial information — transaction amounts, deposit and withdrawal history, masked payment identifiers (e.g. partially masked bKash or Nagad number) and account balance. Full card numbers and mobile banking PINs are never stored by 2l89.
• ▸Gaming activity — bet history, session data, wagering amounts, wins and losses, bonus usage and responsible gaming tool activations such as deposit limits and self-exclusion events.
• ▸Technical and device information — IP address, device type, operating system, browser type, approximate location (city or region level, not precise GPS) and session timestamps, collected automatically when you access the Platform.
• ▸Communications data — content of support tickets, live chat messages and emails you send to 2l89, retained to resolve your query and improve our service quality.

We do not knowingly collect sensitive personal data such as religious beliefs, political opinions, biometric data or health data. If you voluntarily disclose sensitive information during a responsible gaming support request, we handle it with heightened care and use it solely for the purpose disclosed.

3. How We Use Your Information

2l89 uses the personal information we collect only for the following purposes. We process your data where we have a lawful basis for doing so, as described in Section 4.

• ▸Account management — to create and maintain your 2l89 player account, process registration, authenticate your identity via OTP, and manage your account settings and preferences.
• ▸Payment processing — to process your BDT deposits and withdrawals via bKash, Nagad, Rocket, Upay and supported Bangladeshi banks, and to maintain accurate transaction records.
• ▸KYC and compliance — to verify your identity and age (21+) before your first withdrawal, and to comply with anti-money laundering obligations applicable to online gaming platforms.
• ▸Fraud prevention and security — to detect, investigate and prevent fraudulent activity, money laundering, collusion, account takeover attempts and other prohibited conduct described in our Terms and Conditions.
• ▸Platform improvement — to analyse anonymised usage data in order to improve Platform performance, user experience, game selection and payment reliability for all Bangladesh players.
• ▸Customer support — to respond to your support requests, resolve disputes and provide account assistance. Support records are retained to ensure service continuity.

4. Legal Basis for Processing

2l89 processes your personal information only where a lawful basis exists. The primary legal bases we rely on are as follows.

• ▸Contractual necessity — processing identity, payment and gaming activity data is necessary to perform the contract between you and 2l89, i.e. to operate your account, process transactions and deliver game access.
• ▸Legal obligation — processing KYC identity data and transaction records is required to comply with anti-money laundering and counter-terrorism financing obligations.
• ▸Legitimate interests — processing device and technical data for fraud prevention, security monitoring and Platform improvement serves 2l89's legitimate interest in operating a safe and reliable platform, balanced against your privacy rights.
• ▸Consent — where we send promotional communications about bonuses or new games, we do so on the basis of your consent. You may withdraw consent at any time by contacting [email protected].

5. Sharing Your Information

2l89 does not sell your personal information to any third party. We share your data only with the following categories of recipients, and only to the extent strictly necessary for the purposes described in this Policy.

• ▸Payment service providers — bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank and other payment partners receive only the transaction data required to process your deposits and withdrawals.
• ▸Game technology providers — licensed studios including Pragmatic Play, Evolution Gaming, PG Soft, NetEnt, Microgaming, Spribe and Ezugi receive session tokens and game launch data to deliver game content. They do not receive your full identity or payment details.
• ▸Identity verification services — KYC document verification may be performed by a regulated third-party provider. Document data is used solely for identity verification and for no other purpose.
• ▸Law enforcement and regulatory authorities — 2l89 may disclose personal information to competent authorities where required by law, court order or regulatory requirement, including lawful requests from anti-money laundering authorities.

6. Payment Data and Financial Information

2l89 processes all financial transactions in Bangladeshi Taka (BDT). Deposit and withdrawal records — including amounts, timestamps, payment method type and transaction reference numbers — are retained as part of your account history for a minimum of five years from the date of each transaction. This retention period is required to comply with financial record-keeping obligations and to support dispute resolution involving payment history.

2l89 does not store your full mobile banking PIN, bKash or Nagad account password, full card number or card CVV. Payment authentication is handled directly by the respective payment service provider using their own secure systems. 2l89 stores only the minimum payment identifiers required to match a withdrawal request to the correct account and method.

7. Cookies and Tracking Technologies

The 2l89 Platform uses cookies and similar tracking technologies to operate core Platform functions and to understand how players use the Platform so we can improve it. The types of cookies we use are described below.

• ▸Essential cookies — strictly necessary for the Platform to function. They enable login sessions, remember your authentication state and support core security features such as CSRF protection. Essential cookies cannot be disabled without breaking Platform functionality.
• ▸Analytics cookies — collect anonymised data about how players navigate the Platform, which games are popular and where technical errors occur. This helps us improve the Platform for all Bangladesh players. Analytics cookies do not identify you personally.
• ▸Preference cookies — remember your Platform settings such as language selection and display preferences so you do not need to re-configure them on each visit.

You can control non-essential cookies through your mobile browser settings. Disabling analytics or preference cookies will not prevent you from using the Platform but may affect some personalisation features. Disabling essential cookies will prevent the Platform from functioning correctly.

8. Data Retention

2l89 retains your personal information for as long as necessary to fulfil the purposes described in this Policy, and thereafter for such periods as required by applicable law or regulation. General retention periods apply as follows: active account data is retained for the duration of your account plus five years after account closure; KYC identity documents are retained for five years from the date of verification; financial transaction records are retained for a minimum of five years from the date of each transaction; support communications are retained for two years from the date of the interaction.

When the applicable retention period expires, 2l89 will securely delete or permanently anonymise your personal information so it can no longer be attributed to you. Where deletion is not immediately technically feasible for data stored in backup systems, 2l89 will isolate that data from further processing until deletion is possible.

9. Your Rights

As a 2l89 Platform user, you have the following rights regarding your personal information. To exercise any of these rights, contact us at [email protected] with a clear description of your request. We will respond within 30 days of receipt.

• ▸Right of access — request a copy of the personal information 2l89 holds about you, along with information about how it is used and with whom it is shared.
• ▸Right of rectification — request correction of any inaccurate or incomplete personal information held on your account. Some corrections can be made directly via account settings.
• ▸Right of erasure — request deletion of your personal information where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and no other lawful basis exists. Legal retention obligations may mean some data must be kept even after an erasure request.
• ▸Right to restrict processing — request that 2l89 restrict processing of your personal information in certain circumstances, for example where you contest the accuracy of the data or have objected to processing based on legitimate interests.
• ▸Right to withdraw consent — where 2l89 processes your information based on consent (e.g. promotional communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

10. Security of Your Information

2l89 implements industry-standard technical and organisational security measures to protect your personal information against unauthorised access, disclosure, alteration or destruction. Our security measures include SSL/TLS encryption for all data in transit between your device and the Platform, encrypted storage of sensitive account data at rest, OTP-based two-factor authentication for account login and withdrawal requests, and strict access controls ensuring personal data is accessible only to authorised 2l89 staff who require it to perform their duties.

While 2l89 takes the security of your data seriously, no online platform can guarantee absolute security against all possible threats. In the event of a data breach likely to result in high risk to your rights and freedoms, 2l89 will notify affected users without undue delay and will take all reasonable steps to contain the breach and mitigate its impact.

11. Children's Privacy

The 2l89 Platform is strictly for adults aged 21 and above. 2l89 does not knowingly collect personal information from any person under the age of 21. If we become aware that personal information has been inadvertently collected from a person under 21, we will immediately delete that information and close the associated account. If you are a parent or guardian and believe your child has registered on 2l89, please contact us immediately at [email protected].

12. Changes to This Policy

2l89 reserves the right to update or amend this Privacy Policy at any time. Where changes are material, we will notify you by posting the updated Policy on the Platform with a revised effective date. For significant changes that materially affect how we use your personal information, we will endeavour to provide more prominent notice, such as a notification on your account dashboard or via your registered mobile number.

Your continued use of the Platform after the effective date of any revised Policy constitutes your acceptance of the updated terms. We recommend reviewing this Privacy Policy periodically to stay informed about how 2l89 protects your information. The date at the top of this Policy indicates when it was last updated.

13. Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or to how 2l89 handles your personal information, please contact our support team. We are committed to resolving privacy queries promptly and transparently. Our support team is available 24 hours a day, 7 days a week, Bangladesh Standard Time (BST, UTC+6).