l445 Privacy Policy
Your Data, Your Rights

This Privacy Policy ("Policy") is published by l445 ("the Platform", "we", "us", "our") and applies to all individuals ("you", "the User", "the Player") who visit, register on, or otherwise interact with the l445 platform accessible at l445.io and any associated mobile or application interfaces.

l445 is committed to handling the personal data of its users — particularly players based in Bangladesh — with the highest standard of care, transparency, and security. This Policy is designed to give you a clear, honest, and complete picture of our data practices so that you can make informed choices about your engagement with the platform.

This Policy covers:

• What categories of personal data l445 collects from registered players and visitors.
• The purposes for which that data is collected and processed.
• The legal basis on which each processing activity rests.
• How and with whom data may be shared.
• How long data is retained and how it is protected.
• The rights you hold over your data and how to exercise them.

This Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, both of which are available on this website and form part of the full agreement between you and l445. By registering an account or using any part of the l445 platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein.

l445 designates a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection regulations. If you have any privacy-related concerns, the DPO can be reached at [email protected], clearly marking your correspondence "Attention: Data Protection Officer".

l445 collects only the personal data that is necessary and proportionate to the purposes described in this Policy. We do not collect personal data speculatively or beyond what is required for a lawful, transparent, and functional gaming platform. The categories of data we collect are set out in the table below:

We do not intentionally collect or process special categories of sensitive personal data (such as health data, biometric data used for identification, religious beliefs, or political opinions) unless you have explicitly provided such information in the context of a responsible gaming or self-exclusion request, in which case it is processed strictly to protect your wellbeing and in accordance with Section 5 of this Policy.

l445 collects personal data through several distinct channels, all of which are described transparently below:

• Direct submission: Data you provide when you register an account, complete identity verification, make a deposit or withdrawal request, contact our support team, or submit a responsible gaming request.
• Automated technical collection: Data collected automatically as you use the platform, including IP addresses, device identifiers, cookie data, session logs, and behavioural analytics gathered through our platform's own analytics infrastructure.
• Payment processors: Transaction confirmation and status data shared by bKash, Nagad, Rocket, Upay, and banking partners when you initiate a deposit or withdrawal, sufficient to confirm the transaction and update your wallet balance.
• Identity verification providers: Where you submit identity documents, our third-party KYC verification partner processes document images and returns a verification result to l445. Document images are handled by the KYC partner under their own strict data security standards.
• Game providers: Session and outcome data from certified game providers (such as Evolution Gaming, Pragmatic Play, and Spribe) is transmitted to l445 in real-time for the purpose of settling wagers, resolving disputes, and maintaining betting integrity.
• Third-party referral sources: If you arrive at l445 via a partner or affiliate link, we may receive a referral identifier to attribute your registration to the referring partner. No personal data beyond the referral token is shared with affiliates.

l445 does not purchase personal data from data brokers, does not scrape personal data from social media platforms, and does not obtain personal data from any source that has not been disclosed in this Policy.

l445 processes your personal data for the following clearly defined purposes. Each purpose is paired with the legal basis that justifies the processing activity (see Section 5 for legal basis definitions):

• Account registration and management: Creating and maintaining your player account, authenticating your login sessions, and enabling you to access the full range of l445 services.
• Identity and age verification: Confirming that you are a real person aged 21 or older and that your account information is accurate and consistent with your identity documents. This is mandatory for all accounts and is required by our operational policies.
• Payment processing: Facilitating deposits into your l445 wallet and processing withdrawal requests to your registered bKash, Nagad, Rocket, or bank account. All financial data is processed exclusively for payment execution and fraud prevention.
• Responsible gaming monitoring: Monitoring account activity for patterns that may indicate problem gambling behaviour, and proactively applying safeguards such as deposit limits, cooling-off periods, or self-exclusion where necessary or requested.
• Fraud prevention and security: Using technical data, device fingerprinting, and behavioural signals to detect and prevent fraudulent account activity, bonus abuse, multi-accounting, and money laundering.
• Customer support: Using communication and account data to respond to your support enquiries, resolve disputes, and provide service-related information efficiently.
• Legal and regulatory compliance: Retaining transaction records, identity documents, and communication logs to satisfy AML obligations, respond to lawful requests from competent authorities, and resolve any regulatory or legal disputes.
• Platform improvement and analytics: Using anonymised and aggregated usage data to understand how players interact with the platform, identify areas for improvement, and develop new features.
• Marketing communications: Where you have explicitly opted in, sending you promotional emails or in-platform notifications about bonuses, seasonal promotions (such as Eid or BPL season offers), new game launches, and platform updates. You may opt out of marketing communications at any time by updating your notification preferences in your account dashboard or by contacting [email protected].

l445 will never use your personal data for any purpose that is incompatible with those listed above without first providing you with clear notice and, where required by law, obtaining your explicit consent.

Each data processing activity carried out by l445 rests on one or more of the following legal bases:

• Contractual necessity: Processing that is required to perform the contract between you and l445 — that is, to deliver the betting and casino services you have registered to use. This covers account management, payment processing, and core service delivery.
• Legal obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering (AML) obligations, age verification requirements, and lawful requests from regulatory or law enforcement authorities.
• Legitimate interests: Processing carried out in pursuit of l445's legitimate operational and commercial interests, provided those interests are not overridden by your fundamental rights and freedoms. This includes fraud detection, platform security, analytics, and internal reporting. We conduct a balancing test before relying on this basis for any new processing activity.
• Consent: Processing that is based on your freely given, specific, informed, and unambiguous agreement. This basis applies primarily to optional marketing communications and to the processing of any special-category data voluntarily provided in the context of a responsible gaming request. You have the right to withdraw consent at any time without affecting the lawfulness of processing that occurred before withdrawal.
• Vital interests: In very limited circumstances — such as where we are concerned that a player may be at serious risk of harm to themselves due to problem gambling — we may process personal data to protect their vital interests. This basis is used rarely and proportionately.

l445 may share your personal data with the following categories of third parties, each operating under strict contractual data protection obligations:

• Payment processors: bKash, Nagad, Rocket, Upay, City Bank, BRAC Bank, Dutch-Bangla Bank, Islami Bank, Sonali Bank, Visa, and Mastercard — to process deposits and withdrawals initiated by you. Shared data is limited to what is required to execute and confirm each transaction.
• KYC and identity verification providers: Third-party verification services that process identity documents and biometric checks on l445's behalf, subject to their own ISO-certified security frameworks and bound by data processing agreements with l445.
• Game providers: Licensed studios including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Ezugi, Spribe, and others, who receive session identifiers and wager data necessary to operate their games within the l445 platform. These providers do not receive your full identity profile.
• Technology and infrastructure partners: Cloud hosting providers, cybersecurity vendors, and platform infrastructure partners who process data strictly on l445's instructions under binding data processing agreements.
• Analytics providers: Privacy-compliant analytics tools that process anonymised or pseudonymised usage data to help l445 understand platform performance. These tools do not receive your identity or financial data.
• Legal and regulatory authorities: Competent courts, law enforcement agencies, financial intelligence units, or other regulatory bodies, where l445 is required by law or a valid legal order to disclose specific data. l445 will notify you of any such request where legally permitted to do so.
• Fraud prevention networks: Industry-standard fraud prevention and responsible gaming databases that allow l445 to screen accounts against known fraudulent identities or self-excluded players.

All third-party processors are required to maintain data security standards consistent with or exceeding those described in this Policy, and are prohibited from using shared data for any purpose other than the specific service they provide to l445.

l445 retains personal data only for as long as it is necessary to fulfil the purposes for which it was collected, or as required by applicable law, whichever is longer. The following retention periods apply as a general guide:

When the applicable retention period expires, personal data is either securely deleted or anonymised such that it can no longer be attributed to any identifiable individual. Anonymised data may be retained indefinitely for statistical and analytical purposes.

l445 implements a comprehensive, multi-layered approach to data security, designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Our security measures include but are not limited to:

• 256-bit SSL/TLS encryption: All data transmitted between your device and the l445 platform is encrypted using industry-standard Transport Layer Security (TLS 1.3). This applies to all account activity, payment transactions, and support communications.
• Encryption at rest: Sensitive personal data — including identity documents, financial records, and password hashes — is stored in encrypted form on our infrastructure. Passwords are hashed using a modern, adaptive hashing algorithm (bcrypt) and are never stored in plain text.
• Access controls: Access to personal data within l445's internal systems is restricted on a strict need-to-know basis. Staff access is governed by role-based permissions, and all access events are logged and subject to periodic audit.
• Device fingerprinting and anomaly detection: Our security systems continuously monitor login and account activity for anomalous behaviour — including unusual login locations, unfamiliar devices, and atypical transaction patterns — and will trigger verification challenges or temporary locks where suspicious activity is detected.
• Two-factor authentication (2FA): l445 offers 2FA for all player accounts. We strongly recommend all players activate 2FA to add an additional layer of protection to their account credentials.
• Regular security assessments: l445 conducts periodic internal security reviews and works with external cybersecurity professionals to identify and remediate vulnerabilities in its platform and infrastructure.
• Data breach response: In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, l445 will notify affected individuals without undue delay and will document the breach, its causes, and the remedial actions taken.

l445 uses cookies and similar tracking technologies on its platform to deliver a functional, personalised, and secure user experience. This section explains what cookies we use, why we use them, and how you can manage your cookie preferences.

What are cookies? Cookies are small text files placed on your device by a website when you visit it. They allow the website to remember information about your visit — such as your session state, language preferences, or device type — so that the experience is smoother and more consistent on repeat visits.

l445 uses the following categories of cookies:

• Strictly necessary cookies: These cookies are essential for the platform to function correctly. They include session cookies that keep you logged in while you navigate between pages, and security cookies that help detect fraudulent activity. These cookies cannot be disabled without significantly impairing your ability to use the platform.
• Functional cookies: These cookies remember your preferences — such as your preferred game category, display settings, or notification choices — to deliver a more personalised experience. Disabling functional cookies may reduce personalisation but will not prevent you from using the platform.
• Analytics cookies: These cookies collect anonymised or pseudonymised data about how players use the platform — such as which pages are most visited, how long sessions last, and where users exit the site. This data is used exclusively for internal analytics to improve the platform. l445 uses privacy-respecting analytics tools that do not share this data with third-party advertising networks.
• Security and fraud-prevention cookies: These cookies support l445's device fingerprinting and behavioural analysis systems, helping to identify suspicious account activity, detect multi-accounting, and prevent bonus abuse. They are classified as strictly necessary due to their role in platform integrity.

l445 does not use third-party advertising cookies, retargeting pixels, or social media tracking cookies. You will not find Facebook Pixel, Google Ads tracking, or similar advertising-network cookies on the l445 platform.

You can manage cookie settings through your browser's built-in privacy controls. Please note that disabling strictly necessary cookies will prevent you from logging in or using core platform features. For a list of specific cookies in use on the l445 platform, contact [email protected].

As a user of the l445 platform, you hold the following rights over your personal data. l445 is committed to honouring these rights promptly and transparently . To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request — [Right Type]":

l445 will respond to all verified data rights requests within 30 calendar days of receipt. In complex cases, this period may be extended by a further 60 days, in which case we will notify you of the extension and the reason for it within the initial 30-day window.

l445 will not charge a fee for processing a data rights request unless the request is manifestly unfounded or excessive, in which case a reasonable administrative fee may apply. We will always notify you before applying any such fee.

To protect your privacy and prevent unauthorised data disclosures, l445 will verify your identity before processing any data rights request. You may be asked to confirm your registered email address, provide a copy of your identity document, or answer security questions associated with your account.

l445 takes its obligations regarding the protection of minors extremely seriously. The following measures are in place to enforce our 21+ age policy:

• All new registrations require submission of a valid government-issued identity document confirming date of birth. Accounts where age cannot be verified to our satisfaction are suspended pending verification.
• Our fraud detection systems are configured to flag accounts showing behavioural indicators inconsistent with adult users, which may trigger enhanced verification checks.
• l445 participates in industry-standard responsible gaming registers that allow parents and guardians to restrict access to online gambling platforms on shared or family devices.
• Any deposits made to an account that is subsequently found to belong to or have been operated by a minor will be fully refunded, and all winnings accrued in the account will be voided. The account will be permanently closed.

If you are a parent or guardian and believe that a minor has registered on or used the l445 platform, please contact us immediately at [email protected] with the subject line "Minor Account Report". We will investigate and take appropriate action within 24 hours of receiving your report.

l445 supports the use of parental control software and internet filtering tools to prevent minors from accessing online gambling content. Widely used tools include Net Nanny, Qustodio, and built-in device screen-time controls available on Android and iOS devices.

As an online platform, l445 operates with the support of technology partners and infrastructure providers whose servers may be located outside Bangladesh. This means that your personal data may be transferred to and processed in countries other than Bangladesh in the course of delivering our services to you.

Where such international transfers occur, l445 takes all reasonable and appropriate steps to ensure that your personal data receives an equivalent level of protection to that afforded within Bangladesh. These steps include:

• Entering into data processing agreements with all international third-party processors that include binding data protection obligations modelled on internationally recognised frameworks.
• Assessing the data protection laws and practices of the destination country before transferring data, and implementing additional safeguards where the level of protection is assessed as insufficient.
• Ensuring that all international data transfers are limited to the minimum data necessary for the specific processing activity, and that data is not retained by international processors beyond the period required to fulfil that activity.

l445's primary infrastructure is hosted within data centres that hold ISO 27001 certification for information security management. All data transfers between l445 systems — whether domestic or international — are protected by encrypted connections.

If you have questions about the specific countries to which your data may be transferred, or would like to review the safeguards applicable to a specific transfer, please contact our Data Protection Officer at [email protected].

l445 reserves the right to update, revise, or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws and regulations, the introduction of new platform features, or feedback from our user community.

When material changes are made to this Policy, l445 will:

• Update the "Last updated" date and version number displayed at the top of this page.
• Publish a notice in the l445 platform dashboard for all logged-in users, summarising the key changes made.
• Where changes are significant and affect how we process data based on your consent, send a direct notification to the email address registered to your account at least 14 days before the updated Policy takes effect.

Your continued use of the l445 platform after the effective date of an updated Privacy Policy constitutes your acknowledgement of the updated terms. If you do not agree with any changes made to this Policy, you may close your account and request deletion of your data in accordance with Section 10 of this Policy.

We recommend reviewing this Policy periodically — particularly during major seasonal periods such as the BPL cricket season, Eid, or Pohela Boishakh, when new platform features or promotional tools may be introduced that could affect data processing practices. The most current version of this Policy is always accessible at l445.io/privacy-policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or to how l445 handles your personal data, please reach out to our team using the contact details below. All privacy-related correspondence should be directed to the Data Protection Officer and will receive a response within two business days (Bangladesh Standard Time, UTC+6).

• Email: [email protected] — Subject line: "Privacy Policy Enquiry" or "Data Rights Request — [Right Type]"
• Live Chat: Available 24/7 directly within your l445 account dashboard
• Response Time: Within 2 business hours via live chat; within 48 hours via email
• Operating Hours: 24 hours a day, 7 days a week, Bangladesh Standard Time (BST, UTC+6)
• Support Languages: English and Bengali

For responsible gaming concerns, self-exclusion requests, or account closure, please mark your email subject line clearly as "Responsible Gaming Request" or "Account Closure Request" so that our dedicated responsible gaming team can prioritise your case.

l445 is committed to resolving all privacy-related complaints fairly, promptly, and transparently. If you feel your concern has not been addressed to a satisfactory standard after contacting our support team, you may escalate the matter by requesting a formal review from our Data Protection Officer, clearly marking your correspondence "Formal Privacy Complaint — Escalation".