lo89 Privacy Policy

1. Introduction

lo89 ("lo89", "we", "us", "our") operates the online casino and sports betting platform accessible at lo89.app. We are committed to protecting the privacy and personal data of every player who uses our platform. This Privacy Policy ("Policy") explains what personal information we collect, why we collect it, how we use and store it, with whom we share it, and what rights you have in relation to your personal data.

This Policy applies to all users of the lo89 platform, including players based in Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, and all other areas of Bangladesh. By creating an account or using any part of the lo89 platform, you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal data as described herein.

2. Information We Collect

lo89 collects personal data through three primary channels: information you provide directly when registering or using the platform, information generated automatically as you use the platform, and information received from third parties involved in delivering our services.

Information you provide directly:

• Registration details: mobile number, full name, date of birth, and any additional information required for identity verification (KYC).
• Identity documents submitted for KYC verification, including national identity card, passport, or other government-issued documents as required.
• Payment account details, including the mobile financial service account numbers (bKash, Nagad, Rocket, Upay) registered in your name for deposit and withdrawal purposes.
• Communications you send to lo89 support, including the content of emails, chat messages, and any supporting documents or screenshots you attach.

Information generated automatically:

• Device and technical data: IP address, device type, operating system, browser type and version, screen resolution, and mobile network operator.
• Usage data: pages visited, games played, bet amounts, session duration, deposit and withdrawal history, bonus activity, and navigation patterns within the platform.
• Cookie and tracking data: session identifiers, preference cookies, analytics identifiers, and similar tracking technologies as described in Section 7.
• Geolocation data: approximate location derived from your IP address or, where you provide explicit consent, precise location from your device's GPS for the purpose of regulatory compliance.

Information received from third parties:

• Identity verification results and fraud risk scores from KYC and AML screening providers engaged by lo89 to fulfil our legal obligations.
• Transaction confirmation and status data from payment processors including bKash, Nagad, and Rocket, used to reconcile deposits and withdrawals against your lo89 wallet.
• Information provided by our marketing partners or referral sources that enables lo89 to attribute your registration to the correct promotional channel, where applicable.

3. How We Use Your Information

lo89 uses the personal data we collect for the following purposes. Where a purpose requires a specific legal basis, that basis is identified in Section 4.

• Account creation and management: to create and maintain your player account, process registrations, verify your identity, and keep your account details up to date.
• Platform delivery: to provide access to games, sports betting markets, and all other features and services available on the lo89 platform.
• Payment processing: to process deposits, withdrawals, and bonus credits in accordance with our Terms and Conditions, and to investigate and resolve any payment disputes.
• Legal and regulatory compliance: to fulfil our obligations under applicable anti-money laundering (AML) laws, to conduct KYC checks, to respond to lawful requests from competent authorities, and to prevent fraud and other criminal activity.
• Responsible gaming: to monitor gameplay patterns and account activity for signs of problem gambling, to enforce deposit limits and self-exclusion requests, and to send responsible gaming communications where appropriate.
• Customer support: to respond to your enquiries, handle complaints, and provide technical assistance in relation to your account or any transactions on the platform.
• Platform improvement and analytics: to analyse usage patterns, test new features, and improve the overall player experience on the lo89 platform. Where analytics are conducted, data is aggregated and anonymised wherever possible.

4. Legal Basis for Processing

lo89 processes personal data only where a valid legal basis exists. The following legal bases apply to our data processing activities:

• Contract performance: processing necessary to create and maintain your player account, deliver the platform services you have requested, process payments, and fulfil our contractual obligations to you under our Terms and Conditions.
• Legal obligation: processing required to comply with applicable law, including AML regulations, KYC requirements, and lawful orders from competent governmental or regulatory authorities.
• Legitimate interests: processing for the purpose of detecting and preventing fraud, abuse of the bonus system, and other prohibited conduct; improving platform security; and conducting anonymised analytics to improve services — where these interests are not overridden by your data protection rights.
• Consent: processing based on your freely given, specific, and informed consent — for example, sending you promotional communications about new bonuses or game launches. You may withdraw consent at any time by contacting support or adjusting your account preferences.

5. Sharing Your Personal Information

lo89 does not sell, rent, or trade your personal data. We share personal data with third parties only where necessary for the purposes described in this Policy, and only with parties who are contractually bound to handle your data securely and confidentially.

We may share your data with the following categories of recipients:

• Payment processors: bKash, Nagad, Rocket, Upay, and other payment service providers used to process your deposits and withdrawals. These providers receive only the minimum data necessary to complete the transaction.
• KYC and identity verification providers: third-party services engaged by lo89 to verify player identity and conduct AML screening as required by applicable law. These providers process identity documents and verification data under strict data protection obligations.
• Game providers: software providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi may receive session and gameplay data necessary for the delivery and integrity of their games. Game providers operate under their own privacy policies and data protection frameworks.
• Law enforcement and regulatory authorities: lo89 will disclose personal data to competent governmental, law enforcement, or regulatory authorities where required to do so by applicable law, court order, or where lo89 reasonably believes such disclosure is necessary to prevent or detect a criminal offence.

6. Payment Data and Financial Information

lo89 handles payment data with the highest level of care. When you make a deposit or request a withdrawal via bKash, Nagad, Rocket, or another supported payment method, lo89 records the transaction reference number, the amount, the timestamp, and the payment account identifier (mobile number) associated with the transaction. lo89 does not store full payment credentials or authenticate directly into your mobile banking account on your behalf.

All payment transactions on the lo89 platform are processed in Bangladeshi Taka (BDT). Financial transaction records are retained for a minimum of five years from the date of the transaction in accordance with applicable AML and financial record-keeping obligations. These records may be required to be produced to competent authorities upon lawful request.

7. Cookies and Tracking Technologies

lo89 uses cookies and similar tracking technologies to operate the platform, remember your preferences, analyse usage, and prevent fraud. A cookie is a small text file stored on your device when you visit the lo89 platform. Cookies do not contain your personal financial data or passwords.

Types of cookies used on lo89:

• Essential cookies: strictly necessary for the platform to function. These cookies enable core features such as session management, authentication, and security. They cannot be disabled without preventing the platform from working correctly.
• Functional cookies: used to remember your preferences such as language selection and display settings, so you do not need to re-enter them on each visit.
• Analytics cookies: used to collect aggregated, anonymised information about how players use the platform, including which pages are most visited and how long sessions last. This data helps lo89 improve platform performance and player experience.
• Security and fraud-prevention cookies: used to identify and flag unusual device behaviour, detect bot activity, and prevent unauthorised access attempts.

You may manage cookie preferences through your mobile browser settings. Note that disabling essential cookies will affect the functionality of the lo89 platform. Disabling analytics or functional cookies will not prevent you from using the platform but may affect your experience.

8. Data Retention

lo89 retains personal data for no longer than is necessary to fulfil the purposes for which it was collected, unless a longer retention period is required or permitted by applicable law. The following general retention periods apply: active player account data is retained for the lifetime of the account plus a period of five years following account closure; financial transaction records are retained for a minimum of five years from the date of each transaction; KYC and identity verification documents are retained for a minimum of five years following the end of the player relationship; communications with customer support are retained for two years from the date of the communication.

When the applicable retention period expires and there is no legal requirement to continue holding the data, lo89 will securely delete or anonymise the relevant personal data. Where deletion is not immediately possible (for example, because data is stored in backup systems), lo89 will isolate the data from further processing until deletion is feasible.

9. Data Security

lo89 takes the security of your personal data seriously and implements a range of technical and organisational measures designed to protect your data against unauthorised access, accidental loss, destruction, or disclosure. These measures include SSL/TLS encryption for all data in transit between your device and lo89 servers; encrypted storage for sensitive data at rest; strict access controls limiting which lo89 personnel can access player personal data; regular security testing and vulnerability assessments of the platform infrastructure; and staff training on data protection obligations and security best practices.

While lo89 implements all commercially reasonable security measures, no system is entirely immune to security threats. In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected players, lo89 will take prompt action to contain the breach, assess its impact, and notify affected players as required by applicable law.

10. Your Data Protection Rights

Subject to applicable law, you have the following rights in relation to the personal data lo89 holds about you. To exercise any of these rights, please contact lo89 support using the details in Section 15. lo89 will respond to all valid rights requests within 30 days of receipt.

• Right of access: you may request a copy of the personal data lo89 holds about you, together with information about how it is being used and with whom it has been shared.
• Right to rectification: if any personal data lo89 holds about you is inaccurate or incomplete, you may request that it be corrected or completed without undue delay.
• Right to erasure: in certain circumstances you may request that lo89 delete your personal data — for example, where the data is no longer necessary for the purpose for which it was collected and there is no overriding legal obligation to retain it.
• Right to restriction: you may request that lo89 restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or where you have objected to processing pending verification of lo89's legitimate grounds.
• Right to object: where lo89 processes your personal data on the basis of legitimate interests, you have the right to object to that processing. lo89 will cease processing unless it can demonstrate compelling legitimate grounds that override your interests or rights.
• Right to withdraw consent: where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

Please note that certain rights are subject to legal exceptions and may not be exercisable in all circumstances. For example, lo89 may be required to retain certain financial and identity data to comply with AML legislation even where a player has requested erasure. lo89 will clearly explain any applicable exception when responding to a rights request.

11. Children's Privacy

The lo89 platform is strictly intended for adults aged 21 years and above. lo89 does not knowingly collect personal data from individuals under the age of 21. If lo89 becomes aware that personal data has been collected from an underage individual, that data will be deleted without undue delay and the associated account will be closed immediately.

12. Third-Party Links

The lo89 platform does not include links to third-party websites for commercial purposes. Where technical integrations with third-party services (such as game providers or payment processors) are in place, those services are accessed through secure API connections rather than through redirects to external websites that would expose your personal data outside of the lo89 environment.

lo89 is not responsible for the privacy practices or the content of any third-party service providers. We encourage you to review the privacy policies of any third-party service you use independently of the lo89 platform.

13. International Data Transfers

lo89 primarily stores and processes player data within infrastructure located in or serving the Asia-Pacific region. In the course of delivering our services, certain data may be processed by third-party providers (such as KYC verification services or analytics tools) whose infrastructure is located in other jurisdictions. Where such transfers occur, lo89 ensures that appropriate safeguards are in place to protect your data, including contractual data protection obligations between lo89 and the relevant service providers.

lo89 does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without first putting in place appropriate contractual safeguards. If you have questions about international data transfers affecting your personal data, please contact lo89 support.

14. Changes to This Privacy Policy

lo89 may update this Privacy Policy periodically to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes to this Policy, we will notify registered players by posting a prominent notice on the lo89 platform or by sending a notification to the contact details associated with your account. The revised Policy will take effect from the date it is published on the platform.

We encourage you to review this Privacy Policy regularly to stay informed about how lo89 protects your personal data. The date at the top of this Policy indicates when it was most recently updated.

15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the personal data lo89 holds about you, please contact the lo89 support team. We handle all privacy-related enquiries with care and will aim to respond within 5 business days (Bangladesh Standard Time, UTC+6).

Please include your registered mobile number, a brief description of your request, and the relevant account details in all privacy-related correspondence to help us handle your enquiry as quickly as possible.