Privacy Policy of 89p14 – How We Protect Your Data

This Privacy Policy describes how 89p14 collects, stores, uses, shares, and protects the personal data of users who access the Sports Betting and online casino platform at 89p14.net. It applies to all services available on 89p14 — Brasileirão betting, UFC, live casino, slots, crash games, and any current or future features.

89p14 acts as the controller of personal data under Brazil's General Personal Data Protection Law (LGPD — Federal Law No. 13.709, of August 14, 2018). This means we are responsible for determining the purposes and means of processing your personal data and for ensuring that such processing is carried out securely, transparently, and within the limits permitted by Brazilian law.

By creating an account on 89p14, you confirm that you have read and understood this Privacy Policy. This policy is supplementary to the Terms and Conditions of 89p14, which also form part of the agreement between you and the platform.

89p14 collects personal data at various points during your interaction with the platform. We organize data collection into the following categories:

Data you provide directly

• Full name, CPF, date of birth, and nationality (required for registration);
• Full residential address in Brazil (street, number, complement, ZIP code, city, and state);
• Email address and mobile number for communication and authentication;
• Government-issued ID (RG, CNH, or passport) and proof of address, collected during the KYC verification process;
• Financial information such as bank account details or the Pix key associated with withdrawals, used solely to process payments.

Data collected automatically during use

• IP address, browser type and version, operating system, and device identifiers (mobile, tablet, or desktop);
• Platform browsing data: pages visited, session duration, clicks, and interactions with the games catalog and betting markets;
• Betting history, results, and account balance — required to operate the platform and detect suspicious patterns;
• Full financial transaction history: deposits via Pix, boleto bancário, card, PicPay, and TED; and completed withdrawals;
• Access logs: date, time, and approximate location of each login to the 89p14 account.

Data from external sources

• Identity verification and anti-fraud information provided by credit bureaus and compliance partners when required for the KYC process;
• Anti-money laundering data obtained from public sanctions lists and applicable regulatory databases in Brazil.

89p14 uses collected personal data exclusively for the purposes described below. We do not use your data for purposes incompatible with what is stated in this Policy:

• Account and platform operation: creating and managing your account, processing Sports Betting wagers and casino plays, crediting and debiting your balance, and personalizing your experience;
• Identity verification (KYC): confirming that you are 18 or older, reside in Brazil, and are who you claim to be — a legal requirement for online Sports Betting and gambling platforms in Brazil;
• Payment processing: processing deposits via Pix, boleto bancário, credit/debit card, PicPay, or TED, and handling withdrawals to your own registered account;
• Fraud and money laundering prevention: detection of anomalous betting and transaction patterns, investigation of suspicious accounts, and fulfillment of mandatory reporting obligations to authorities as required by law;
• Customer support: handling your questions, complaints, and requests via live chat or email, with interaction records kept for quality assurance;
• Account communications: sending emails and notifications about transactions, changes to terms, VIP Program promotions, and other information relevant to your use of the platform — you can manage your communication preferences from your account dashboard;
• Ongoing platform improvement: aggregated and anonymized analysis of usage behavior to identify usability issues, optimize performance, and develop new features;
• Responsible gaming: monitoring of usage patterns that may indicate problem gambling behavior, to trigger alerts and control tools available to all users.

The LGPD requires that every instance of personal data processing have a specific legal basis. 89p14 processes your data on the following grounds set out in Law 13.709/2018:

89p14 does not sell, rent, or trade users' personal data. Sharing only occurs in the cases below, all of which are duly justified:

• Payment processors: financial institutions and intermediaries such as Pix (Banco Central do Brasil), PicPay, Mercado Pago, card operators, and banks (Nubank, Itaú, Bradesco, Banco do Brasil) receive the minimum data necessary to process each transaction;
• Game providers: casino and Sports Betting software providers (such as Evolution Gaming, Pragmatic Play Live, Spribe, and NetEnt) receive an anonymized session identifier to record game round results — with no access to your name, CPF, or full financial details;
• Identity verification (KYC) partners: credit bureaus and providers specializing in digital onboarding receive the data necessary to validate your identity and prevent fraud, under strict confidentiality agreements;
• Competent authorities: the Financial Activities Control Council (COAF), the Banco Central do Brasil, the Receita Federal, and other regulatory or judicial authorities may receive data when required by law or court order — no data subject consent is required in these cases;
• Technology infrastructure providers: cloud services, security monitoring, and data analytics operating under contract with 89p14 as data processors, with no authority to use your information for their own purposes.

All third parties that access 89p14 user data are bound by contractual agreements requiring the secure and confidential handling of that information, in compliance with the LGPD.

89p14 implements technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or improper disclosure. Key measures include:

• 256-bit SSL/TLS encryption on all communications between your device and 89p14's servers;
• Data stored on security-certified servers, with access restricted to authorized personnel via multi-factor authentication;
• Sensitive data segmentation — CPF information, KYC documents, and financial data are stored in isolated environments with additional access controls;
• Continuous monitoring of unauthorized access attempts, with automatic alerts to 89p14's security team;
• Periodic vulnerability testing and security audits conducted by independent specialists;
• An internal information security training program for all 89p14 staff who access user data.

89p14 retains your personal data for as long as necessary to fulfill the purposes stated in this Policy and to meet applicable legal obligations. The general retention criteria are:

• Active account data: retained for as long as your account is active or for as long as necessary to provide the contracted services;
• Financial transaction history: retained for at least 5 years after each transaction, as required by anti-money laundering legislation (Law 9.613/1998) and the regulations of the Banco Central do Brasil;
• KYC documents: retained for at least 5 years after account closure, in accordance with regulatory obligations;
• Access and security logs: retained for 6 months as required by the Brazilian Internet Civil Framework (Law 12.965/2014), and may be extended for fraud investigation or ongoing litigation purposes;
• Support communication data: retained for 2 years after the support interaction is closed, for quality assurance and dispute resolution purposes.

Once applicable retention periods have expired, 89p14 anonymizes or securely deletes personal data, making it impossible to retrieve on an individual basis.

89p14 uses cookies and similar technologies to improve your browsing experience, ensure the platform functions correctly, and analyze usage behavior in aggregated form. The types of cookies we use are:

• Essential cookies: required for the basic operation of the platform — maintaining login sessions, language preferences, and security. They cannot be disabled without impairing your use of 89p14;
• Performance cookies: collect aggregated and anonymized information about how users navigate the platform (most visited pages, session duration, errors encountered) to improve 89p14's performance;
• Functional cookies: remember your usage preferences (such as the last sport or game you accessed) to deliver a more personalized experience;
• Analytical cookies: used by internal analytics tools to understand how different platform features are used — always based on anonymized data.

89p14 does not use third-party advertising cookies or share browsing behavior data with external ad networks. Cookie preferences can be managed through the account settings panel or your browser settings. Disabling non-essential cookies does not affect access to 89p14's core features.

The LGPD grants you, as the data subject whose personal data is processed by 89p14, a comprehensive set of rights that may be exercised at any time. 89p14 is committed to responding to all requests within 15 business days:

To exercise any of these rights, please contact 89p14's Data Protection Officer by email at contato@89p14.net, stating the right you wish to exercise and providing sufficient information to verify your identity.

Some of 89p14's technology partners — particularly casino software providers and cloud infrastructure vendors — may be located outside Brazil. When personal data is transferred abroad, 89p14 ensures that such transfers take place with appropriate safeguards, in compliance with Article 33 of the LGPD:

• The destination countries offer a level of personal data protection equivalent to that of the LGPD; or
• The transfer is carried out under standard contractual clauses that require the recipient to handle the data with the same level of protection required in Brazil; or
• The transfer is necessary for the performance of the service agreement between you and 89p14.

In all cases, internationally transferred data is limited to the minimum necessary for the specific purpose — such as an anonymized session identifier used to record the outcome of a game round on the game provider's server, without your full personal data.

89p14 is a platform exclusively for users aged 18 and over. We do not knowingly collect personal data from anyone under 18. Registration requires a date of birth, and accounts created with a date of birth indicating an age below 18 are blocked immediately.

If you believe a person under 18 has created an account on 89p14 or provided personal data to the platform, please contact us by email at contato@89p14.net immediately. 89p14 will promptly delete any data collected from minors once identified.

89p14 may update this Privacy Policy to reflect changes in its services, applicable Brazilian law, or data processing practices. The date of the most recent update is always shown at the top of this page.

Significant changes — such as the addition of new processing purposes or new types of data collected — will be communicated at least 15 days in advance by email and/or via an in-platform notification on 89p14. For minor corrections or clarifications, updating the date at the top of the page is sufficient.

Continued use of 89p14's services after an updated version of this Policy takes effect constitutes acceptance of the new terms. If you do not agree with the changes, you must close your account and request a withdrawal of your available balance before the new version's effective date.

Pursuant to Article 41 of the LGPD, 89p14 has appointed a Data Protection Officer (DPO) responsible for serving as the communication channel between data subjects, 89p14, and the National Data Protection Authority (ANPD).

The 89p14 Data Officer is responsible for:

• Receive and respond to data subjects' requests regarding the exercise of rights guaranteed under the LGPD;
• Receive communications from the ANPD and take the necessary measures;
• Guide the 89p14 team on personal data protection practices;
• Coordinate the response to security incidents involving personal data;
• Prepare and keep up to date the Data Protection Impact Assessment (DPIA) when required.

To contact the 89p14 Data Protection Officer, send an email to contato@89p14.net with the subject line "Data Protection Officer – LGPD". Requests are responded to within 15 business days.

For any questions, requests to exercise your rights, or complaints related to the processing of your personal data by 89p14, you can reach us through the following channels:

• Data Officer Email: contato@89p14.net — for formal requests regarding access, correction, deletion, portability, or withdrawal of consent. Response time: up to 15 business days;
• Live chat: available 24 hours a day on 89p14 after login, for quick questions about privacy and data use. Average response time: under 3 minutes;
• Help Center: 89p14.net/faq — answers to the most frequently asked questions about privacy, cookies, and data protection.

If you believe 89p14 is processing your data in violation of the LGPD and have not received a satisfactory response through the channels above, you have the right to file a complaint directly with the National Data Protection Authority (ANPD) through the official ANPD portal (the Brazilian government authority responsible for overseeing LGPD compliance).

This Privacy Policy is governed by the laws of the Federative Republic of Brazil. For matters not resolved directly with 89p14, the courts of the judicial district of São Paulo — SP are designated as the competent venue to settle any disputes arising from the processing of personal data by 89p14.