89db Privacy Policy — How We Protect Your Data

This Privacy Policy ("Policy") describes how 89db ("we", "us", "our") collects, uses, stores, shares and protects the personal data of players and visitors who use the 89db platform at https://89db.vu (the "Platform"). 89db is committed to handling all personal data responsibly, lawfully and transparently.

By accessing or using the 89db Platform, you acknowledge that you have read this Policy and understand how your personal data is handled. If you do not agree with this Policy, you should not use the Platform. This Policy should be read together with the 89db Terms & Conditions, which govern your use of the Platform as a whole.

89db is the data controller responsible for your personal data collected through the Platform. If you have any questions about how we handle your data, or wish to exercise any of your rights described in this Policy, you may contact us using the details below:

89db collects personal data that you provide directly, data that is generated automatically when you use the Platform, and data that we receive from third-party payment processors and game providers. The categories of data we collect are set out below:

You are not obliged to provide all categories of data, but failure to provide data that is required for account registration, KYC verification or payment processing may prevent you from using certain features of the Platform, including the ability to deposit, withdraw or access your full account.

89db uses your personal data only for the purposes set out below. We do not use your data for any purpose that is incompatible with these stated purposes without your explicit consent:

• To create and manage your 89db account, including processing your registration, verifying your identity and age (21+), and managing your account settings.
• To process deposits and withdrawals in BDT via your chosen payment method (bKash, Nagad, Rocket, Upay or other approved methods) and to maintain accurate financial records.
• To comply with our anti-money laundering (AML) and know-your-customer (KYC) obligations, including verifying your identity and monitoring transactions for suspicious activity.
• To provide customer support, respond to your enquiries and resolve disputes or complaints about your account or any transactions.
• To improve the Platform, including analysing usage patterns, debugging technical issues and optimising performance for Bangladeshi mobile networks and devices.
• To send you account-related communications (e.g. deposit confirmations, withdrawal notifications, security alerts) and, where you have consented, promotional communications about bonuses, new games or seasonal offers.

89db processes your personal data on the following legal bases:

• Contract performance — processing that is necessary for us to fulfil our obligations to you under the Terms & Conditions, including account management, game access and payment processing.
• Legal obligation — processing that is required for compliance with AML, KYC, fraud prevention and other legal obligations applicable to online gaming operators.
• Legitimate interests — processing that serves our legitimate business interests (e.g. fraud detection, platform security, analytics) where those interests are not overridden by your rights and freedoms.
• Consent — where we send you marketing communications or use non-essential cookies, we do so only with your prior consent. You may withdraw consent at any time by contacting [email protected] or adjusting your browser cookie settings.

89db may share your personal data with the following categories of third parties, strictly limited to what is necessary for the purposes described in this Policy:

• Payment processors — bKash, Nagad, Rocket, Upay and other approved payment service providers, for the sole purpose of processing your deposit and withdrawal transactions. These providers have their own privacy policies governing the data they hold.
• Game providers — Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi and other licensed game studios, limited to the session and technical data required to serve games to your device.
• Fraud prevention and AML compliance services — third-party identity verification and transaction monitoring services used to fulfil our KYC and AML obligations. These services process your data under contractual confidentiality obligations.
• Regulatory and law enforcement authorities — where we are required by law, court order or regulatory authority to disclose your personal data. 89db will disclose only the minimum data required to comply with such a request.

All third parties to whom 89db discloses personal data are required to keep that data confidential and to use it only for the specific purpose for which it was disclosed. 89db does not permit third parties to use your data for their own independent purposes.

89db retains records of transaction amounts, dates, payment method type and transaction reference numbers for financial reporting, AML compliance and dispute resolution purposes. This transaction history data is associated with your account and retained for the period described in Section 9 of this Policy.

All deposit and withdrawal transactions at 89db are denominated in Bangladeshi Taka (BDT). No currency conversion data is collected or stored, as the Platform operates exclusively in BDT for players in Bangladesh.

89db uses cookies and similar tracking technologies on the Platform. A cookie is a small text file placed on your device when you visit a website. 89db uses the following categories of cookies:

• Essential cookies — strictly necessary for the Platform to function, including session management, login state and security tokens. These cookies cannot be disabled without breaking core Platform functionality.
• Analytics cookies — used to understand how players use the Platform, which pages are most visited, and how players navigate between sections. This data is aggregated and anonymised where possible. Analytics cookies are set only with your consent.
• Preference cookies — used to remember your settings and preferences on the Platform, such as language selection. These are set only where necessary to provide a personalised experience.

You may control or delete cookies through your browser settings. Please note that disabling essential cookies will prevent you from logging in or using key Platform features. For detailed instructions on managing cookies on the most common mobile browsers used in Bangladesh (Chrome for Android, Samsung Internet, Opera Mini), please consult your browser's help documentation.

89db retains your personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

• Account data (registration details, KYC documents) — retained for the lifetime of your account and for a period of 5 years following account closure, in accordance with AML record-keeping obligations.
• Transaction data (deposit and withdrawal records) — retained for a minimum of 5 years following each transaction, for financial reporting and AML compliance purposes.
• Technical and analytics data (IP logs, session data) — retained for up to 12 months, after which it is anonymised or deleted.

Where your data is no longer required for any of the above purposes, 89db will securely delete or anonymise it. You may request earlier deletion of your account data (subject to legal retention obligations) by contacting [email protected].

As a user of 89db, you have the following rights in relation to your personal data. To exercise any of these rights, please contact us at [email protected] with your registered mobile number and a description of your request:

• Right of access — you may request a copy of the personal data that 89db holds about you. We will provide this within a reasonable timeframe, typically within 30 days of your verified request.
• Right to rectification — if you believe that any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it. Minor corrections (e.g. typos in name or address) can often be made directly from your account settings.
• Right to erasure — you may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations (particularly AML record-keeping requirements).
• Right to restrict processing — in certain circumstances you may request that we restrict the processing of your personal data (e.g. while a dispute about its accuracy is being resolved).
• Right to object — where we process your data on the basis of legitimate interests, you have the right to object to that processing. We will cease processing unless we can demonstrate compelling legitimate grounds that override your rights.
• Right to withdraw consent — where processing is based on consent (e.g. marketing emails), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

89db will respond to all data rights requests within 30 days. Where a request is complex or there are a large number of requests, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reasons for it.

89db implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction or alteration. These measures include 256-bit SSL/TLS encryption for all data transmissions, encrypted storage of account data at rest, role-based access controls limiting staff access to personal data on a need-to-know basis, and regular security audits.

While 89db takes all reasonable steps to protect your personal data, no method of electronic storage or internet transmission is 100% secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, 89db will notify affected players promptly in accordance with applicable notification obligations.

If you believe that a person under 21 has registered an account on 89db, please contact us immediately at [email protected]. We take child protection and underage gambling prevention seriously and will act on any such report without delay.

The 89db Platform may contain references to third-party game providers, payment services or other external services. 89db does not control the privacy practices of any third-party service and is not responsible for their privacy policies or data handling. We encourage you to review the privacy policy of any third-party service before providing them with your personal data. The presence of a reference to a third-party service on the 89db Platform does not constitute an endorsement of that service's privacy practices.

89db reserves the right to update this Privacy Policy at any time. When we make material changes, we will update the "Last Updated" date at the top of this Policy and, where appropriate, notify registered players by placing a notice in their account or by sending a communication to their registered mobile number. We encourage you to review this Policy periodically.

Your continued use of the 89db Platform following the publication of a revised Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree to the revised Policy, you must stop using the Platform and may request account closure by contacting [email protected].

For all privacy-related enquiries, data access requests, correction requests, deletion requests or complaints about how 89db handles your personal data, please contact our support team. We aim to acknowledge all privacy enquiries within 24 hours Bangladesh Standard Time (BST, UTC+6) and to resolve them within 30 days.