lb111 Privacy Policy — How We Handle Your Personal Data

Introduction

lb111 ("we", "us", "our", or "the Platform") is committed to protecting the privacy of all players who register and play on lb111.app. This Privacy Policy sets out the types of personal data we collect from you when you use lb111, the purposes for which we use that data, the parties with whom we may share it, and the rights you have in relation to your personal data. Please read this policy carefully before registering an account with lb111.

By creating an lb111 account and using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein. If you do not agree with this Privacy Policy, you must not use lb111. This policy applies to all players in Bangladesh and any other jurisdiction from which lb111 is accessible.

Your Privacy at a Glance

The following cards summarise the most important aspects of how lb111 handles your data. Full details are provided in the sections below.

2. What Personal Data We Collect

lb111 collects personal data in several ways: directly from you when you register or use the Platform, automatically as you interact with the Platform, and from third-party payment processors who confirm your transactions. The categories of personal data we collect are described below.

3. How We Use Your Personal Data

lb111 uses the personal data we collect only for the purposes listed below. We do not use your data for any purpose that is incompatible with these stated purposes.

• To create and manage your lb111 player account, verify your identity in accordance with our KYC obligations, and maintain the security of your account at all times.
• To process your deposits and withdrawals via bKash, Nagad, Rocket, and Upay, reconcile transactions, and investigate any payment disputes you raise with lb111 support.
• To deliver and improve our gaming products, personalise your lb111 experience based on your game preferences and activity, and develop new features relevant to Bangladeshi players.
• To detect, investigate, and prevent fraud, money laundering, bonus abuse, cheating, collusion, and any other prohibited activity that may harm lb111 or other players on the platform.
• To comply with our responsible gaming obligations, including monitoring play patterns that may indicate problem gambling, enforcing deposit limits, self-exclusion periods, and time-out requests set by players.
• To send you service communications related to your lb111 account, including deposit confirmations, withdrawal notifications, security alerts, and updates to our Terms and Conditions or Privacy Policy. lb111 does not send unsolicited marketing communications to players.

4. Legal Basis for Processing

lb111 processes your personal data on the following legal grounds, in accordance with applicable data protection principles.

• Contractual necessity: processing your registration data, payment data, and gaming activity data is necessary to provide you with the lb111 service and to fulfil our contractual obligations to you as set out in the lb111 Terms and Conditions.
• Legitimate interests: processing technical and device data for fraud prevention, platform security, and responsible gaming monitoring constitutes a legitimate interest of lb111 that is proportionate and not overridden by your privacy rights.
• Legal obligation: processing your identity data for KYC verification and retaining transaction records is necessary to comply with applicable anti-money laundering, counter-terrorism financing, and data retention obligations.
• Consent: where lb111 sends you any optional communications or uses your data for a purpose beyond those described above, we will obtain your explicit consent before doing so. You may withdraw consent at any time by contacting [email protected].

5. Sharing Your Personal Data

lb111 does not sell, rent, or trade your personal data to any third party. We share your personal data only in the limited circumstances described below, and only to the extent necessary for the stated purpose.

• Payment processors: lb111 shares transaction reference data with bKash, Nagad, Rocket, and Upay solely for the purpose of processing and confirming your deposits and withdrawals. These providers are bound by their own strict data protection policies and applicable Bangladeshi financial regulations.
• Game providers: lb111 may share a pseudonymous player identifier (not your name or contact details) with game studios such as Pragmatic Play, Evolution Gaming, Spribe, Ezugi, and Microgaming to facilitate game delivery, RNG certification, and fair play auditing.
• Legal and regulatory authorities: lb111 may disclose personal data to law enforcement agencies, regulatory bodies, or courts when required to do so by applicable law, court order, or lawful request. lb111 will notify affected players of such disclosures where legally permitted to do so.
• Fraud prevention and security partners: in cases of suspected fraud, money laundering, or account compromise, lb111 may share relevant account data with specialist fraud prevention services or financial intelligence units as required by applicable law and regulation.

6. Payment Data and Mobile Wallet Security

When you make a deposit to lb111 via bKash, Nagad, Rocket, or Upay, the payment transaction is initiated and authenticated within your mobile wallet application. lb111 receives a transaction confirmation and reference number from the payment processor — it does not receive, store, or have access to your mobile banking PIN, password, or biometric authentication data at any point.

lb111 records the mobile wallet number you use for each deposit transaction. This is used to route withdrawal payments back to the correct wallet and to comply with anti-money laundering requirements that mandate same-source withdrawal policies. You should therefore ensure that the mobile wallet you use for deposits is registered in your own name and matches your lb111 account registration details.

7. Data Retention

lb111 does not retain your personal data for longer than is necessary for the purposes for which it was collected, subject to any legal obligations that require us to retain data for a minimum statutory period.

• Account data (registration details, KYC documents) is retained for the duration of your lb111 account and for a period of 5 years following permanent account closure, to satisfy anti-money laundering statutory retention requirements.
• Transaction records (deposit and withdrawal history) are retained for a minimum of 5 years from the date of the transaction, in accordance with applicable financial record-keeping obligations.
• Technical and device data (IP logs, session data) is retained for a rolling period of 12 months from the date of collection, unless it forms part of an active fraud investigation, in which case it is retained until the investigation is concluded.

8. How We Protect Your Data

lb111 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include 256-bit SSL/TLS encryption on all data transmissions between your device and lb111 servers, secure server infrastructure with access controls and monitoring, regular security assessments of our platform and data handling processes, and internal access controls that restrict access to personal data to authorised lb111 personnel only on a need-to-know basis.

While lb111 takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security against all possible threats. If you believe your lb111 account has been compromised, you should contact our support team immediately at [email protected] and change your account password. lb111 will investigate any reported security incident promptly and take all necessary steps to contain and remediate any breach.

9. Your Data Rights

As a player on lb111, you have the following rights in relation to the personal data we hold about you. To exercise any of these rights, please contact our support team at [email protected]. We will respond to all data rights requests within 30 days of receipt.

• Right of access: you may request a copy of all personal data lb111 holds about you. We will provide this in a structured, commonly used electronic format within 30 days of your verified request.
• Right to rectification: if any personal data lb111 holds about you is inaccurate or incomplete, you may request that we correct or update it. We will action all verified rectification requests within 14 days.
• Right to erasure: subject to our legal data retention obligations, you may request that lb111 delete the personal data we hold about you. We will action erasure requests for data that is no longer necessary for its original purpose and where no legal retention obligation applies.
• Right to restriction: you may request that lb111 restrict the processing of your personal data in certain circumstances, for example while a rectification request is being assessed or while a dispute regarding our use of your data is pending resolution.
• Right to object: where lb111 processes your personal 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 interests, rights, and freedoms.

To exercise any of the rights above, please send a written request to [email protected] with the subject line "Data Rights Request" and include your registered lb111 mobile number for identity verification purposes. lb111 will not charge a fee for processing data rights requests submitted in good faith.

10. Cookies and Tracking Technologies

lb111 uses a small number of essential cookies to operate the platform. These cookies are strictly necessary for core platform functions, including maintaining your logged-in session, remembering your language preference, and preserving your responsible gaming settings between visits. lb111 does not use advertising cookies, third-party tracking pixels, behavioural profiling cookies, or any cookie that tracks your activity across other websites.

Because lb111 uses only technically essential cookies, we do not present a cookie consent banner. If you disable cookies in your mobile browser, some platform features (including maintaining your login session) may not function correctly. For the best lb111 experience, we recommend keeping cookies enabled in your browser settings.

11. Children and Minors

lb111 operates a strict 21+ age policy and does not knowingly collect personal data from any person under the age of 21. Registration on lb111 requires confirmation that the applicant is 21 years of age or older. If lb111 discovers that personal data has been collected from a person under 21, that account will be immediately closed, all data associated with the account will be deleted (subject to legal retention obligations), and any funds in the account will be handled in accordance with applicable law. If you are a parent or guardian and believe that a minor may have registered with lb111, please contact us immediately at [email protected].

12. Changes to This Privacy Policy

lb111 reserves the right to update or amend this Privacy Policy at any time. When we make material changes to this policy, the revised version will be posted at lb111.app/privacy-policy with an updated effective date. We encourage you to review this page periodically. Your continued use of lb111 after the posting of a revised Privacy Policy constitutes your acceptance of the updated policy. If you do not agree with any change to this Privacy Policy, you should stop using lb111 and may request account closure by contacting [email protected].

13. Contact and Data Enquiries

If you have any questions about this Privacy Policy, wish to exercise your data rights, or need to report a privacy concern, please contact the lb111 support team. We are available 24/7 and will respond to all privacy-related enquiries as promptly as possible and in any case within 72 hours.