Privacy Policy of 289wim: your data truly protected

1. Data Controller

289wim is the controller of personal data collected from players registered on the platform at 289wim.best. For the purposes of the General Data Protection Law (LGPD — Law No. 13.709/2018), 289wim is responsible for all decisions regarding the processing of your personal data — including the purpose, collection methods, and retention period for each piece of information.

289wim's Data Protection Officer (DPO) can be reached at suporte@289wim.best or via the platform's live chat for matters related to privacy, exercising rights guaranteed under the LGPD, or reporting any situation that puts your personal data security at risk.

2. Data We Collect

289wim collects only the data strictly necessary for the platform to function, to verify player identities, and to fulfill applicable legal obligations. The data collected falls into the following categories:

3. How We Use Your Data

Every piece of data collected by 289wim has a specific, documented purpose. We use your data to:

• Create and manage your account — verify your identity, ensure only one account exists per CPF, and maintain secure access to the platform;
• Process bets and games — recording every bet, calculating results, crediting winnings, and keeping a complete history available in your dashboard;
• Process payments — enabling deposits via Pix, boleto bancário, credit/debit card, PicPay, Mercado Pago, and TED bank transfer, and processing withdrawals to registered accounts;
• Identity verification (KYC) — meet legal obligations related to anti-money laundering and counter-terrorism financing under Brazilian law;
• Responsible gambling — monitor usage patterns that may indicate problematic behavior and trigger alerts or protective tools when necessary;
• Player support — answering questions, resolving disputes, and handling complaints based on the player's account history;
• Account communications — send bet confirmations, withdrawal notifications, security alerts, and Terms and Conditions updates;
• Marketing communications — send promotions, weekly bonuses, and 289wim news — only with your explicit consent, and with the option to opt out at any time;
• Security and fraud prevention — detect and investigate suspicious activity, multiple accounts, and platform misuse;
• Legal obligations — comply with requirements from competent authorities, including the Central Bank of Brazil and the Federal Revenue Service, when legally required.

4. Legal Basis for Processing

289wim processes your personal data based on the legal grounds set out in the LGPD. The applicable legal basis for each purpose described above is:

• Contract performance — processing required to deliver 289wim's platform services, including account management, bet processing, and payments;
• Compliance with a legal or regulatory obligation — KYC verification, anti-money laundering compliance, and reporting to competent authorities when required by law;
• Legitimate interest — platform security, fraud prevention, responsible gambling monitoring, and continuous improvement of 289wim's services;
• Consent — sending marketing communications and using non-essential cookies — with the option to withdraw consent at any time without affecting your use of the platform.

5. Data Sharing

289wim does not sell players' personal data. Information is shared only in the situations below, always with the applicable contractual and legal safeguards in place:

• Certified payment processors — to process deposits and withdrawals via Pix, boleto, credit/debit card, and TED transfers. These partners are PCI-DSS certified and handle only the financial data strictly necessary for each transaction;
• Identity Verification Providers (KYC) — specialized platforms for document and selfie verification, used to fulfill customer identification obligations required under Brazilian law;
• Game and casino providers — developers of the slots, live casino, and table games available on 289wim receive only the technical data required to run the games — with no access to players' financial or sensitive personal data;
• Competent authorities — the Banco Central do Brasil, Receita Federal, COAF (Financial Activities Control Council), or any other public authority with a legal mandate to request information. In such cases, 289wim discloses only the data specifically requested, within the limits of the law;
• Group companies — any affiliated or subsidiary companies involved in operating the 289wim platform, always subject to the same security and privacy policies.

6. Data Retention and Deletion

289wim retains your personal data for as long as necessary for each specific purpose, in accordance with the deadlines established by Brazilian law:

• Account and registration data — retained for the duration of the active account and for up to 5 years after closure, in accordance with anti-money laundering requirements (Law No. 9.613/1998);
• Financial transaction history — deposits, withdrawals, and betting history are retained for up to 5 years after the last transaction, in compliance with applicable tax and regulatory obligations;
• Support communication records — retained for up to 3 years for audit purposes and resolution of any disputes;
• KYC data — identity verification documents are retained for the minimum period required by anti-money laundering legislation — generally 5 years after the end of the relationship with 289wim;
• Marketing data — retained only while consent remains active. After consent is withdrawn, data is removed from communication lists within up to 30 days.

Once retention periods expire, data is securely deleted or anonymized so that it can no longer be linked to a specific individual.

7. Information Security

289wim implements technical and organizational measures to protect your personal data against unauthorized access, loss, alteration, or improper disclosure. The key measures currently in place include:

• 256-bit SSL encryption across all communications between users and 289wim's servers;
• Passwords stored with secure hashing — 289wim never stores your password in plain text and has no access to your original password;
• Two-factor authentication (2FA) available and encouraged for all players on the platform;
• Continuous monitoring of access and suspicious access attempts with automatic blocking;
• Role-based internal access controls — each 289wim team member can only access the data required for their specific role;
• Regular security audits conducted by specialized external teams;
• A documented security incident response plan, with designated responsible parties and notification timelines in compliance with the LGPD.

8. Cookies & Tracking

289wim uses cookies and similar technologies to ensure the platform runs correctly, improve the player experience, and — with your consent — analyze platform usage. The cookies used fall into the following categories:

• Essential cookies — required for the basic operation of the 289wim platform, such as keeping your login session active, remembering language preferences, and securing transactions. These cannot be disabled without impairing your use of the platform;
• Performance and analytics cookies — collect information about how players use the platform (most visited pages, session duration, errors encountered) in an aggregated and anonymized form. Used to continuously improve 289wim. Activated only with your consent;
• Personalization cookies — allow the platform to remember your gaming preferences, favorite games, and account settings for a more personalized experience. Activated only with your consent;
• Marketing cookies — used to measure the effectiveness of advertising campaigns and present relevant 289wim content. Activated only with explicit consent.

You can manage your cookie preferences at any time through the platform's privacy dashboard or your browser settings. Disabling non-essential cookies does not affect access to 289wim's core features.

9. Your Rights as a Data Subject (LGPD)

Brazil's General Data Protection Law (LGPD — Law No. 13.709/2018) guarantees you, as the data subject whose personal data is processed by 289wim, the following rights:

• Access: request a copy of all personal data 289wim holds about you, including the purpose of processing and any third parties with whom it has been shared;
• Correction: request corrections to inaccurate, incomplete, or outdated data;
• Deletion: request the deletion of data processed on the basis of your consent. For data processed under other legal grounds (such as legal obligation), deletion may be limited by mandatory retention periods;
• Portability: receive your data in a structured, commonly used, machine-readable format, where technically feasible;
• Sharing information: know exactly which third parties your data has been or will be shared with;
• Consent withdrawal: withdraw consent previously given for processing based on that legal basis, without affecting the lawfulness of prior processing or your ability to use the platform's core features;
• Objection: object to processing carried out on the basis of legitimate interest when there are valid grounds to do so;
• ANPD complaint: file a complaint with the Autoridade Nacional de Proteção de Dados (ANPD) if you believe your rights have been violated.

To exercise any of these rights, contact 289wim support via live chat or by email at suporte@289wim.best, specifying the right you wish to exercise along with your identification details. Requests are processed within up to 15 business days as required by the LGPD.

10. Protection of Minors

The 289wim platform is intended exclusively for users aged 18 and over. 289wim does not knowingly collect personal data from minors and does not permit registration or use of the platform by anyone under that age.

Upon registration, the user expressly declares they are 18 years of age or older. If 289wim determines that data from a minor was collected in error, the following measures will be taken immediately:

• Immediate account access suspension;
• Deletion of all personal data associated with the account;
• Refund of the real deposit balance to the identified legal guardian, where applicable;
• Internal notification for review of age verification procedures.

Any report of 289wim platform use by a minor must be submitted immediately to support via live chat or by email at suporte@289wim.best.

11. Changes to This Privacy Policy

289wim may update this Privacy Policy periodically to reflect changes in Brazilian data protection legislation, the platform's data processing practices, or new regulatory requirements.

Any material changes will be communicated to active 289wim players by email and in-platform notification at least 7 days before the effective date. For substantial changes involving new data processing or revised stated purposes, affected players will be asked for their explicit consent.

The current version of this Privacy Policy is always available at 289wim.best/privacy-policy. The date of the last update is indicated at the top of this page. Continued use of the 289wim platform after the effective date constitutes acknowledgment of the updates made.

12. Contact the Data Protection Officer (DPO)

289wim's Data Protection Officer is responsible for receiving communications from data subjects and the Autoridade Nacional de Proteção de Dados (ANPD), as well as guiding the internal team on personal data protection practices in compliance with the LGPD.

To exercise your rights as a data subject, get answers about how 289wim handles your data, or report any privacy concern, please get in touch:

• Live chat: available on the 289wim platform, 24 hours a day, 7 days a week. Ask to be directed to the privacy channel for matters related to personal data;
• Email: suporte@289wim.best — with the subject line "Privacy and Personal Data". Response time: up to 15 business days.

289wim is committed to handling every rights request seriously and responding in a clear, straightforward manner within the legal deadlines set by the LGPD. If you are not satisfied with the response, you have the right to file a complaint directly with the National Data Protection Authority (ANPD).