lc44 Privacy Policy — Your Data, Protected

This Privacy Policy ("Policy") describes how lc44 ("lc44", "we", "us", "our") collects, processes, stores, and protects the personal data of individuals ("you", "your", "Player", "User") who register for and use the lc44 online betting and live casino platform, accessible at lc44.io and through any associated mobile interface.

This Policy is intended to provide you with a clear and comprehensive understanding of our data practices. It applies to all personal data collected in connection with your use of the lc44 platform, including account registration, deposits and withdrawals, sports betting, casino game play, customer support interactions, and any promotional communications you have consented to receive.

This Policy should be read alongside our Terms & Conditions and our Responsible Gaming Policy, both of which are incorporated by reference and form part of the overall agreement governing your use of the lc44 platform.

We may update this Policy from time to time to reflect changes in our data practices, applicable law, or business operations. The "Last Updated" date at the top of this page indicates when the most recent revision was made. Where changes are material, we will notify you via a prominent platform notice or by email to your registered address. Continued use of lc44 following notification of any update constitutes acceptance of the revised Policy.

lc44 collects personal data across several categories depending on how you interact with the platform. The following table summarises the categories of data we collect and the primary source of each:

lc44 does not intentionally collect sensitive categories of personal data such as health information, religious beliefs, political opinions, or biometric data, except where a liveness or document verification check is required as part of the KYC process — in which case the data is used solely for identity verification and is not retained beyond the verification period.

lc44 uses your personal data for the following purposes, each of which is necessary to deliver a safe, compliant, and high-quality platform experience for Bangladeshi players:

• Account Creation and Management: Processing your registration, verifying your identity and age (21+ compliance), maintaining your account profile, and communicating account-related notices to you.
• Transaction Processing: Facilitating deposits and withdrawals via bKash, Nagad, Rocket, and Upay; recording financial transactions; preventing payment fraud; and fulfilling our financial record-keeping obligations.
• Platform Delivery: Enabling access to all lc44 products including cricket betting, live casino, slots, and table tennis markets; personalising your in-platform experience based on your game history and preferences.
• KYC and Regulatory Compliance: Conducting identity, age, and source-of-funds verification in accordance with our responsible gaming and anti-money-laundering obligations.
• Fraud Detection and Security: Monitoring account activity for signs of unauthorised access, multi-accounting, automated betting, collusion, and other prohibited conduct as defined in our Terms & Conditions.
• Customer Support: Responding to your queries, resolving disputes, processing responsible gaming requests (deposit limits, self-exclusion, cooling-off), and maintaining records of support interactions.
• Marketing and Promotions: Sending you promotional offers, bonus notifications, and seasonal campaign information (e.g., BPL, T20 World Cup, Eid, Pohela Boishakh promotions) where you have provided consent to receive such communications. You may withdraw consent at any time via account settings or by contacting support.
• Platform Improvement: Analysing aggregated usage data to understand how players interact with lc44, identify technical issues, and improve the performance and design of the platform.
• Legal and Compliance Obligations: Retaining records as required by applicable law, responding to lawful requests from regulatory or law enforcement authorities, and enforcing our Terms & Conditions.

lc44 processes your personal data on one or more of the following legal bases depending on the specific purpose of the processing activity:

• Contractual Necessity: Processing that is necessary to perform our contract with you — specifically, to operate your lc44 account, process your deposits and withdrawals, and deliver the betting and gaming services you have registered for.
• Legal Obligation: Processing required to comply with applicable legal and regulatory obligations, including anti-money-laundering checks, age verification requirements, and financial record-keeping mandates.
• Legitimate Interests: Processing carried out to protect lc44's legitimate business interests, including fraud detection, security monitoring, platform improvement, and the enforcement of our Terms & Conditions — provided these interests are not overridden by your data protection rights.
• Consent: Processing that relies on your explicit consent, most notably the sending of marketing and promotional communications. Where consent is the legal basis, you retain the right to withdraw it at any time without affecting the lawfulness of prior processing.

Where lc44 relies on legitimate interests as the legal basis for processing, we conduct a balancing assessment to ensure that your fundamental rights and freedoms are given appropriate weight alongside lc44's operational needs. If you would like more information about any specific balancing assessment, please contact [email protected].

lc44 does not sell your personal data. We may share your data with the following categories of recipients only to the extent strictly necessary for the stated purpose:

• Payment Service Providers: bKash, Nagad, Rocket, and Upay receive transaction data necessary to process your deposits and withdrawals. These providers operate under their own privacy policies and are independently responsible for their data handling practices.
• Game Providers: Third-party casino game studios (including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Ezugi, and Spribe) may receive a session token and minimum technical data required to launch and authenticate game sessions on the lc44 platform. Game providers do not receive your full identity profile.
• Identity Verification Partners: KYC and document verification service providers may process identity documents and verification data on lc44's behalf as data processors operating under strict contractual data protection obligations.
• Analytics and Platform Infrastructure Providers: Technical service providers supporting lc44's hosting, platform performance monitoring, and aggregated usage analytics operate as data processors under binding data processing agreements that prohibit independent use of your data.
• Regulatory and Law Enforcement Authorities: Where lc44 is subject to a lawful legal obligation, court order, or regulatory request, we may be required to disclose personal data to competent authorities. lc44 will endeavour to notify you of any such disclosure where legally permitted to do so.
• Professional Advisers: Lawyers, auditors, and financial advisers engaged by lc44 may receive personal data on a need-to-know basis under professional confidentiality obligations.

lc44 uses cookies and similar tracking technologies to operate the platform, maintain your logged-in session, and gather anonymised usage analytics that help us improve the lc44 experience for all players. The following categories of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the lc44 platform to function. They maintain your authenticated session, store your language and region preferences, and enable core security features such as CSRF protection. These cookies cannot be disabled without fundamentally impairing your ability to use lc44.
• Functional Cookies: These cookies remember your platform preferences (e.g., preferred game categories, display settings) to provide a more personalised experience. Disabling these cookies may cause some personalisation features to stop working.
• Analytics Cookies: These cookies collect anonymised information about how players interact with the lc44 platform — which pages are visited most frequently, how long sessions last, and where technical errors occur. This data is used in aggregate form only and cannot be used to identify you individually.
• Security Cookies: These cookies support fraud detection and account security monitoring by identifying unusual access patterns across multiple sessions or device types.

Most web browsers allow you to control cookies through their settings. You may block or delete cookies at any time via your browser's privacy settings. However, please note that disabling strictly necessary cookies will prevent you from logging in to and using the lc44 platform. lc44 does not use third-party advertising or retargeting cookies.

lc44 retains your personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention periods apply:

• Active Account Data: Identity, contact, and financial data associated with an active lc44 account is retained for the full duration of the account relationship.
• Post-Closure Retention: Following voluntary or involuntary account closure, lc44 retains core account and transaction records for a minimum of five (5) years to comply with financial record-keeping and anti-money-laundering obligations.
• KYC Documentation: Identity verification documents are retained for a minimum of five (5) years from the date of verification or account closure, whichever is later.
• Support Records: Customer support interaction records (live chat transcripts, emails) are retained for up to three (3) years from the date of the interaction.
• Analytics Data: Aggregated, anonymised usage analytics data may be retained indefinitely as it cannot be used to identify individual players.
• Marketing Consent Records: Records of marketing consent and opt-out requests are retained for a minimum of three (3) years from the date of the consent action.

At the end of applicable retention periods, personal data is securely deleted or irreversibly anonymised. Anonymised data may be retained for statistical and platform improvement purposes after this point.

lc44 implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security framework includes:

• SSL/TLS Encryption: All data transmitted between your browser or device and lc44 servers is encrypted using industry-standard SSL/TLS protocols across every page and every transaction.
• Encrypted Data Storage: Sensitive personal data — including identity documents, financial records, and authentication credentials — is stored in encrypted form on lc44's secured infrastructure.
• Access Controls: Access to personal data within lc44 is restricted on a strict need-to-know basis. Staff and contractor access is governed by role-based permissions, and all access to sensitive data is logged and audited.
• Intrusion Detection and Monitoring: lc44 operates continuous security monitoring systems that detect and alert on anomalous access patterns, potential intrusion attempts, and account-level security events in real time.
• Vulnerability Management: lc44 conducts regular security assessments and maintains a vulnerability patching programme to address identified risks in a timely manner.
• Staff Training: All lc44 personnel with access to personal data are trained on data protection obligations and information security best practices.

While lc44 takes every reasonable step to protect your personal data, no data transmission over the internet can be guaranteed to be 100% secure. In the event of a data security incident that is likely to result in a high risk to your rights and freedoms, lc44 will notify you without undue delay in accordance with applicable data protection obligations.

As a lc44 player, you have the following rights in respect of your personal data held by lc44. To exercise any of these rights, please contact our support team at [email protected] with your registered account email address and a description of your request.

• Right of Access: You may request a copy of the personal data lc44 holds about you, together with information about how that data is used and with whom it has been shared.
• Right to Rectification: You may request that we correct any inaccurate or incomplete personal data we hold about you. In many cases, you may update basic account information directly within your lc44 account dashboard.
• Right to Erasure: You may request that we delete your personal data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent (and no other legal basis applies), or where you successfully object to our processing. Note that this right may be limited where lc44 is subject to overriding legal retention obligations.
• Right to Restriction: You may request that we restrict the processing of your personal data in certain circumstances — for example, where you contest the accuracy of the data or where you have objected to processing pending our assessment of your objection.
• Right to Data Portability: Where processing is based on your consent or on contractual necessity and is carried out by automated means, you may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You may object at any time to processing carried out on the basis of lc44's legitimate interests. We will stop that processing unless we can demonstrate compelling legitimate grounds that override your interests or the processing is necessary for the establishment, exercise, or defence of legal claims.
• Right to Withdraw Consent: Where processing is based solely on your consent (e.g., marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of any processing carried out before the withdrawal.

lc44 will respond to all valid data rights requests within thirty (30) days of receipt. In complex cases, we may extend this period by a further two months, in which case we will notify you of the extension and the reason for it within the initial thirty-day period. lc44 will not charge a fee for exercising your data rights unless a request is manifestly unfounded or excessive.

The lc44 platform is strictly intended for adults aged 21 years and above. lc44 does not knowingly collect, process, or retain personal data from any individual under the age of 21. Age verification is a mandatory step in the account registration and KYC process, and lc44 will suspend any account where there is reasonable evidence that the holder is under the minimum age.

If you believe that lc44 has inadvertently collected personal data from a person under the age of 21, please contact us immediately at [email protected]. Upon confirmation, lc44 will take prompt action to delete the relevant data and close the associated account, with any deposited funds returned to the verified originating payment account after investigation.

lc44 operates primarily to serve players in Bangladesh. However, some of the third-party service providers we engage — including game providers, infrastructure partners, and KYC verification services — may process data on servers located outside of Bangladesh. Where personal data is transferred internationally, lc44 takes steps to ensure that appropriate safeguards are in place to protect your data to a standard equivalent to that described in this Policy.

Such safeguards may include contractual data processing agreements with standard data protection clauses, binding corporate rules, or transfers to jurisdictions that provide an equivalent level of data protection. If you would like more specific information about the safeguards in place for any specific international transfer, please contact us at [email protected].

The lc44 platform may, on occasion, reference or display the names of third-party payment services (such as bKash, Nagad, and Rocket) or game providers (such as Pragmatic Play, Evolution Gaming, and NetEnt) in the context of describing available products and deposit methods. lc44 does not embed outbound links to external websites in its platform content, and this Privacy Policy does not govern the data practices of any third-party organisation.

If you choose to access the website or application of any third-party provider referenced on lc44 — for example, to manage your bKash account — you do so under that provider's own privacy policy and terms of service. lc44 accepts no responsibility for the privacy practices, content, or security of any third-party platform. We encourage you to read the privacy policy of any third-party service you use in connection with your lc44 account.

lc44 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing activities, applicable law, or our business operations. The most current version of this Policy will always be available at lc44.io/privacy-policy. The "Last Updated" date displayed at the top of this page will be revised whenever material changes are made.

Where a change is material — meaning it significantly affects how we collect or use your personal data, or materially alters your rights under this Policy — lc44 will provide advance notice by displaying a prominent banner on the platform or by sending a notification to your registered email address at least fourteen (14) days before the change takes effect.

For non-material changes (such as clarifications of existing language, corrections of typographical errors, or administrative updates), lc44 may update this Policy without prior notice, with the revised version becoming effective immediately upon publication. Your continued use of the lc44 platform after any update to this Policy constitutes your acceptance of the revised terms. If you disagree with any updated provisions, you must cease using the platform and contact support to request account closure.

If you have any questions, concerns, or requests relating to this Privacy Policy or to lc44's handling of your personal data, please reach out to our support team using any of the channels below. All privacy-related inquiries are handled by our dedicated data protection team, and we aim to acknowledge all requests within two (2) business days.

• Live Chat: Available 24/7 directly inside your lc44 account dashboard after login — the fastest way to reach us for urgent privacy concerns.
• Email: [email protected] — for formal data rights requests and privacy inquiries. Please include "Privacy Request" in the subject line along with your registered account email address.
• WhatsApp: +880 1700-000000 — available during extended support hours for general queries.
• Support Hours: 24/7, 365 days a year, Bangladesh Standard Time (BST, UTC+6).

When submitting a data rights request, please provide your registered username, the email address associated with your lc44 account, a clear description of the right you wish to exercise, and any relevant transaction or account reference numbers that may assist us in locating the relevant data efficiently.