dc89 Privacy Policy

dc89 ("dc89", "we", "us", "our") is committed to protecting the privacy of every individual who accesses or uses the dc89 platform at https://dc89.io (the "Platform"). This Privacy Policy describes in full how dc89 collects, uses, stores, shares, and protects personal data provided by or generated by users of the Platform, including registered account holders, visitors, and prospective players.

This Privacy Policy applies to all data processing activities conducted by dc89 in connection with the Platform and the services offered through it, including account registration, identity verification (KYC), deposits and withdrawals, gameplay, customer support, and marketing communications where you have provided consent.

This Privacy Policy should be read alongside the dc89 Terms and Conditions, which govern your use of the Platform more broadly. By registering a dc89 account or by continuing to use the Platform, you confirm that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein.

For the purposes of this Privacy Policy, dc89 acts as the data controller in respect of personal data collected and processed through the Platform. As data controller, dc89 determines the purposes for which and the means by which personal data is processed.

If you have any questions, concerns, or requests relating to the processing of your personal data by dc89, you may contact us at the following address:

• Platform: dc89.io
• Email: [email protected] (plain text — not a clickable link)
• Support Hours: 24 hours a day, 7 days a week
• Response Time for Privacy Requests: Within 10 business days of receipt

dc89 may appoint a dedicated data protection contact for handling formal privacy requests. Where this is the case, details will be updated in this section of the Privacy Policy.

dc89 collects personal data that falls into the following categories. The specific data points collected depend on the services you use and the interactions you have with the Platform.

dc89 does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data unless specifically required for a legally mandated identity verification process and only with your explicit consent where required.

dc89 collects personal data through the following means:

• Directly from you: When you register an account, complete the KYC process, make a deposit or withdrawal request, contact support, or respond to a promotion.
• Automatically: When you access the Platform, our servers automatically record technical data including your IP address, device identifiers, and session activity through server logs and cookies (see Section 8).
• From payment processors: When you initiate a transaction via bKash, Nagad, Rocket, or Upay, the relevant mobile financial service provider transmits limited transaction confirmation data to dc89 to enable funds to be credited or debited on your account.
• From identity verification partners: Where dc89 engages a regulated third-party KYC provider to assist with identity verification, that provider may supply dc89 with a verification result and relevant supporting information.
• From fraud prevention services: dc89 may receive risk signals or flags from fraud detection services used to protect the platform and its players.

dc89 processes your personal data only where there is a valid legal basis for doing so. The primary purposes for which dc89 processes personal data, together with the corresponding legal basis for each, are set out below:

• Account creation and management: Processing is necessary for the performance of the contract between you and dc89 (the Terms and Conditions you agreed to upon registration).
• Identity and age verification (KYC): Processing is necessary for dc89 to comply with its legal obligations, including age verification requirements. Players must be 21 years of age or older. dc89 cannot fulfil its duty of care without verifying this.
• Payment processing — deposits and withdrawals: Processing is necessary for performance of the contract and to prevent fraud and financial crime.
• Customer support: Processing is necessary for the performance of the contract and dc89's legitimate interest in resolving player issues effectively.
• Fraud prevention and platform security: Processing is based on dc89's legitimate interest in protecting the platform, its players, and the integrity of its games from fraudulent or unlawful activity.
• Responsible gaming compliance: Processing is necessary for dc89 to meet its legal and ethical obligations regarding player protection, including monitoring for signs of problem gambling behaviour.
• Marketing communications (where applicable): Processing is based on your explicit consent. You may withdraw consent at any time by contacting dc89 support.
• Legal and regulatory compliance: Processing is necessary to comply with applicable laws and to respond to lawful requests from regulatory or law enforcement authorities.

dc89 does not sell, rent, or commercially transfer your personal data to any third party. Personal data is shared only in the following limited and controlled circumstances:

• Payment processors: bKash, Nagad, Rocket, Upay, and their respective banking partners receive only the transaction data necessary to process your deposit or withdrawal. Each provider operates under its own privacy and data security policies.
• Identity verification providers: Where a regulated KYC partner is engaged to assist with the verification of your identity, that provider will receive the identity documents you submit and will return a verification result to dc89.
• Game content providers: Game studios and live casino providers whose content is accessible through dc89 may receive limited session data (such as a pseudonymous player ID and bet amounts) required to deliver the gaming experience. These providers do not receive your name, contact details, or financial information.
• Fraud and security services: dc89 may share technical identifiers (such as IP addresses or device fingerprints) with third-party fraud detection and cybersecurity services for the purpose of protecting the platform.
• Legal and regulatory authorities: dc89 may disclose personal data to relevant authorities where required to do so by applicable law, court order, or regulatory instruction. dc89 will not provide advance notice to the account holder where doing so would compromise a legal investigation.
• Corporate transactions: In the event of a merger, acquisition, or sale of assets involving dc89, personal data held by dc89 may be transferred to the relevant successor entity, subject to equivalent privacy protections being maintained.

All third-party service providers with whom dc89 shares personal data are required to process that data only for the specific purposes authorised by dc89 and in accordance with applicable data protection standards. dc89 maintains data processing agreements with its service providers where required by applicable law.

dc89 accepts deposits and processes withdrawals exclusively through Bangladeshi mobile financial services (MFS): bKash, Nagad, Rocket, and Upay. All transactions are denominated in Bangladeshi Taka (৳). dc89 does not accept credit or debit card payments and does not store credit card data.

When you initiate a payment transaction on dc89, the following data handling applies:

• Your mobile wallet number is stored in your dc89 account profile for the purpose of routing withdrawals back to the correct account. dc89 does not store your MFS wallet PIN or any authentication credentials.
• Transaction amounts, dates, references, and confirmation statuses are recorded in dc89's transaction logs for account reconciliation, withdrawal verification, and compliance purposes.
• dc89 does not have access to your MFS account history beyond the transactions that are initiated directly on the dc89 Platform.
• For large or unusual transactions, dc89 may request documentary evidence of source of funds in accordance with anti-money laundering (AML) compliance obligations.

dc89 uses cookies and similar tracking technologies to operate, maintain, and improve the Platform. A cookie is a small text file placed on your device by your web browser when you visit a website. dc89 uses the following categories of cookies:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They manage your login session, maintain your account state across pages, and enable core security features. These cookies cannot be disabled without preventing you from using the Platform.
• Functional Cookies: These cookies remember your preferences (such as your preferred language, display settings, or last-used payment method) to provide a more personalised experience on return visits.
• Analytics Cookies: dc89 uses anonymised analytics data to understand how players navigate the Platform, which pages are most visited, and where technical errors occur. This helps dc89 identify and resolve usability issues. Analytics data is aggregated and does not identify individual users.
• Security Cookies: These cookies are used by dc89's fraud detection systems to identify unusual patterns of access that may indicate account takeover attempts, bot activity, or other malicious behaviour.

You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will prevent you from logging into your dc89 account. dc89 does not use third-party advertising or retargeting cookies to track your activity across other websites.

dc89 applies a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• TLS/SSL encryption: All data transmitted between your device and the dc89 Platform is encrypted using industry-standard Transport Layer Security (TLS) protocols.
• Password hashing: Account passwords are stored using one-way cryptographic hashing algorithms. dc89 does not store plaintext passwords at any point.
• Access controls: Access to personal data held by dc89 is restricted to authorised personnel who require access to perform their specific job functions. Access is logged and subject to periodic review.
• Infrastructure security: dc89's servers and data infrastructure are protected by firewalls, intrusion detection systems, and regular security patching.
• Incident response: dc89 maintains a data breach response procedure. In the event of a confirmed data breach that poses a risk to your rights and interests, dc89 will notify affected users within a reasonable timeframe in accordance with applicable requirements.

While dc89 takes all reasonable steps to protect your personal data, no transmission over the internet or electronic storage system is completely secure. You are responsible for maintaining the security of your dc89 login credentials and for ensuring that you access the Platform from secure, trusted devices and networks.

dc89 retains personal data for no longer than is necessary to fulfil the purpose for which it was collected, or as required by applicable legal, regulatory, or compliance obligations. The general retention periods applied by dc89 are as follows:

• Account data (identity, contact, KYC documents): Retained for the duration of the account relationship plus a minimum of 5 years following account closure, in accordance with AML and record-keeping requirements.
• Transaction records (deposit and withdrawal logs): Retained for a minimum of 5 years from the date of the transaction.
• Gaming session logs: Retained for a minimum of 3 years from the date of the session for dispute resolution and audit purposes.
• Support communications: Retained for 2 years from the date of the last communication in the relevant support thread.
• Technical / server logs: Retained for a maximum of 12 months, after which they are automatically purged or anonymised.
• Responsible gaming records (self-exclusion, limit settings): Retained for the duration of the exclusion or limit period, plus 5 years, to prevent re-registration in breach of an active exclusion.

When a retention period expires, dc89 will securely delete or irreversibly anonymise the relevant personal data so that it can no longer be attributed to any identifiable individual. Where deletion is not immediately practicable (for example, data held in automated backup systems), the data will be isolated from active processing and deleted at the earliest available opportunity.

As a dc89 account holder, you have the following rights in respect of the personal data dc89 holds about you. To exercise any of these rights, contact dc89 support at [email protected] with the subject line "Privacy Rights Request". dc89 will respond within 10 business days.

• Right of Access: You have the right to request a copy of the personal data dc89 holds about you, together with information about how and why it is being processed.
• Right to Rectification: If you believe that any personal data dc89 holds about you is inaccurate or incomplete, you have the right to request that it be corrected or updated.
• Right to Erasure: You may request that dc89 delete your personal data where it is no longer necessary for the purpose it was collected, where you withdraw consent (and no other legal basis applies), or where the data has been processed unlawfully. This right is subject to dc89's legal retention obligations — data that must be retained by law cannot be deleted on request.
• Right to Restriction of Processing: In certain circumstances, you may request that dc89 restrict the processing of your personal data while a dispute about its accuracy or lawfulness is being resolved.
• Right to Data Portability: Where processing is based on your consent or on the performance of a contract, you may request that dc89 provide your personal data in a structured, commonly used, machine-readable format.
• Right to Withdraw Consent: Where dc89 processes your data based on your consent (for example, for marketing communications), you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing that occurred before the withdrawal.
• Right to Object: You have the right to object to processing based on dc89's legitimate interests. dc89 will assess whether its legitimate interests override your rights and will cease processing if they do not.

The dc89 Platform is strictly intended for adults aged 21 years and above. dc89 does not knowingly collect, solicit, or process personal data from individuals under the age of 21. The Platform is not directed at minors and dc89 takes active steps to prevent underage access through age verification procedures applied at registration and during the KYC process.

If dc89 becomes aware that personal data has been collected from an individual under the age of 21, dc89 will immediately close the relevant account, refund any unplayed deposits to the originating mobile wallet, and delete all associated personal data as promptly as practicable, subject to any mandatory legal retention requirements.

If you are a parent or guardian and believe that your child has registered an account on dc89 without your knowledge, please contact dc89 support immediately at [email protected] so that appropriate action can be taken without delay.

dc89 primarily serves players in Bangladesh and stores data on infrastructure located in or operated for the benefit of the dc89 platform. In certain circumstances — for example, where dc89 engages a third-party service provider whose servers are located outside Bangladesh — your personal data may be transferred to and processed in a country other than Bangladesh.

Where such international transfers occur, dc89 takes steps to ensure that appropriate safeguards are in place to protect your personal data to a standard equivalent to the protections described in this Privacy Policy. These safeguards may include contractual data protection clauses, adequacy assessments, or other transfer mechanisms recognised under applicable law.

By using the dc89 Platform and accepting this Privacy Policy, you consent to the transfer of your personal data to countries outside Bangladesh where necessary for the operation of the Services, provided that such transfers are carried out in accordance with the safeguards described above.

dc89 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or the way in which dc89 operates. The most current version of the Privacy Policy will always be published at https://dc89.io/privacy-policy and will carry the "Last Updated" date shown at the top of this page.

Where amendments are material — meaning they significantly affect how dc89 collects, uses, or shares your personal data — dc89 will make reasonable efforts to notify active account holders via their registered contact details prior to the changes taking effect. For minor amendments (such as clarifications of existing practices or updates to contact details), changes will take effect immediately upon publication without prior notification.

Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any changes to this Privacy Policy, you should stop using the Platform and contact dc89 support to close your account.

If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data dc89 holds about you, please contact the dc89 privacy team using the details below. All privacy-related enquiries are handled confidentially and within the response times stated in this Policy.

• Email: [email protected] — Please use the subject line "Privacy Enquiry" for general questions or "Privacy Rights Request" for formal data subject requests.
• Platform: https://dc89.io
• Support Availability: 24 hours a day, 7 days a week including Bangladeshi public holidays.
• Response Time: General enquiries within 3 business days; formal data subject requests within 10 business days (Bangladesh Standard Time, UTC+6).