889a Privacy Policy – Your Data Protected

1. Data Controller

The controller of the personal data collected through the platform 889a (accessible at 889a.click) is the operating company behind the 889a brand. For matters related to personal data processing, you can reach us at contato@889a.click or via the live chat available 24 hours a day on the site.

This Privacy Policy describes how the 889a collects, uses, stores, protects, and may share the personal data of platform users. By creating an account and using the services of 889a, you confirm that you have read and understood this policy. If you do not agree with any part of this document, you must not use the platform.

2. Data We Collect

The 889a only collects the data necessary to deliver the service safely and with quality. The categories of data collected are listed below:

2.1. Data We Do Not Collect

The 889a does not collect sensitive data such as racial or ethnic origin, religious beliefs, health data, genetic data, biometrics, sexual orientation, or trade union membership. We also do not collect full credit card numbers — only partial data for identity confirmation purposes, where necessary.

3. Purpose of Processing

The personal data collected by the 889a are used exclusively for the following purposes:

• Account creation & management: verify eligibility, create the user profile, and maintain secure access to the platform;
• Payment processing: process deposits via Pix, boleto bancário, credit/debit card, PicPay, Mercado Pago, and TED, and execute withdrawals to registered accounts;
• Identity verification (KYC): confirm the account holder's identity and prevent fraudulent account creation;
• Fraud and money laundering prevention: monitor transactions in compliance with Brazilian anti-money laundering legislation;
• Service delivery and improvement: personalize the experience, fix bugs, and improve the platform based on usage behavior;
• Operational communications: send notifications about transactions, security updates, and changes to terms;
• Marketing communications (with consent): send promotions, bonuses, and updates — only to users who have opted in to receive this type of communication;
• Compliance with legal obligations: fulfill requests from competent authorities when legally required.

4. Legal Basis for Processing

As required by the LGPD, all personal data processing by the 889a has a specific legal basis:

• Contract performance: data required to create and maintain your account, process deposits and withdrawals, and deliver the contracted services;
• Legal obligation: data required to comply with anti-money laundering requirements, identity verification, and other regulatory obligations;
• Legitimate interest: browsing data and behavioral data for fraud detection, platform security and service improvement — always in respect of the user's rights and expectations;
• Consent: data used for marketing communications — you can withdraw this consent at any time through your account settings or by contacting support.

5. Data Sharing with Third Parties

The 889a does not sell or transfer personal data to third parties for commercial purposes. Sharing only occurs in the situations below, with partners who have signed data protection agreements compatible with the LGPD:

• Payment processors: data required to process deposits and withdrawals (Pix, boleto, card, PicPay, Mercado Pago, TED) is shared with the respective payment processors only to the extent necessary to complete the transaction;
• Game providers: username and betting history may be shared with providers such as Evolution Gaming, Pragmatic Play, and PG Soft to enable game functionality and resolve technical disputes;
• KYC tools: identity documents may be processed by partners specialized in identity verification to streamline the process without compromising security;
• IT Infrastructure: hosting and server security providers have limited access to the data necessary to deliver their infrastructure services;
• Competent authorities: data may be shared with government, judicial, or regulatory authorities when required by law or court order.

6. Cookies and Tracking Technologies

The 889a uses cookies and similar technologies to enhance the platform experience. Here are the types used:

6.1. Essential Cookies

Required for the basic operation of the platform — session management, authentication, and security. They cannot be disabled without affecting your use of the service.

6.2. Performance Cookies

They collect anonymous information about how users navigate the platform — which pages are visited most often and where errors occur. This data helps improve the experience without identifying individual users.

6.3. Preference Cookies

These store your language preferences, interface settings, and other personalizations so you do not have to reconfigure them on every visit.

6.4. Marketing Cookies (with consent)

Used only with your explicit consent to personalize promotional and bonus communications. You can manage or revoke this consent at any time via the cookie banner or your account settings.

The 889a does not use third-party cookies for tracking outside the platform. Information collected via cookies is handled with the same protections applied to all personal data described in this policy.

7. Data Retention

The 889a retains personal data only for as long as necessary for the purposes described in this policy, or for the period required by law. The general retention criteria are:

• Active account data: retained for as long as the account is active or as long as required to provide the service;
• Financial transaction data: retained for up to 5 years after the transaction, in accordance with Brazilian anti-money laundering and tax legislation;
• KYC verification data: retained for up to 5 years after account closure, as required by regulation;
• Support records: kept for up to 2 years for dispute resolution and service improvement purposes;
• Browsing and behavior data: anonymized after 12 months of account inactivity.

Once the retention period ends, data is securely and permanently deleted, with a deletion certificate available upon request.

8. Data Security

The 889a implements robust technical and organizational measures to protect your personal data against unauthorized access, loss, alteration, or destruction:

• 256-bit SSL/TLS Encryption across all communication between devices and servers;
• Encryption at rest for data stored in databases — even unauthorized physical access to the server does not expose readable data;
• Role-based access control — only staff with a specific need may access defined categories of data;
• Real-time monitoring of access and transactions, with automatic alerts for suspicious patterns;
• Periodic penetration testing conducted by external specialists to identify and fix vulnerabilities before they can be exploited;
• Encrypted backups performed regularly at geographically separate locations to ensure availability and recovery in the event of an incident;
• Multi-factor authentication required for all internal staff access to systems containing personal data.

In the event of a security incident involving personal data, the 889a will activate its Incident Response Plan, notify affected users by email, and report the incident to the ANPD within the legally required 72-hour window from the moment of awareness.

9. How to Exercise Your Rights

To exercise any of the rights guaranteed by the LGPD — access, correction, deletion, portability, objection, restriction or information — please contact the 889a through one of the channels below:

• Live chat: available 24 hours a day on the website, in Portuguese — the fastest option for urgent matters;
• Email: contato@889a.click — for formal requests, please include your full name, CPF and a detailed description of your request.

The 889a will respond to rights exercise requests within 15 business days. In cases requiring additional identity verification, the deadline may be extended by a further 15 days, with prior notice to the requester. If a request is refused for a legitimate reason (such as a legal retention obligation), we will explain the grounds in writing.

10. Minors

The platform 889a is intended exclusively for users aged 18 and over. The 889a does not knowingly collect personal data from users under 18. If we become aware that a minor's data has been inadvertently collected, we will delete that data immediately and close the corresponding account.

If you believe your child or dependent under the age of 18 has created an account on 889a, please contact our support team immediately. We will handle your case with priority and full discretion. Legal guardians may request the deletion of data belonging to minors in their care at any time.

11. International Data Transfers

In some cases, personal data may be transferred to servers or partners located outside Brazil — for example, cloud infrastructure providers or game providers headquartered abroad. When this occurs, the 889a ensures that:

• The transfer takes place only to countries with an adequate level of data protection recognized by the ANPD, or;
• The recipient has signed standard contractual data protection clauses compatible with the LGPD, or;
• The user has given specific consent for the transfer, where required.

The 889a prioritizes partners with infrastructure in Brazil whenever available, to minimize unnecessary international data transfers.

12. Changes to this Privacy Policy

The 889a may update this Privacy Policy periodically to reflect changes in data practices, regulatory updates, or service improvements. The update date at the top of this page always indicates the current version.

For significant changes that affect user rights, the 889a will notify registered users by email at least 7 days before any changes take effect. Continued use of the platform after the new terms come into force constitutes acceptance of the updated policy.

13. Contact and Data Protection Officer (DPO)

The 889a has appointed a Data Protection Officer (DPO), as required by the LGPD for large-scale data processing operations. The DPO is the point of contact for all data privacy matters, for both users and the ANPD.

To reach the DPO of 889a or for any questions related to this Privacy Policy:

• Email: contato@889a.click (subject: "Data Privacy / LGPD")
• Live chat: available 24 hours a day on the 889a website, in Portuguese

The 889a is committed to responding to all privacy-related communications within 5 business days for general inquiries, and within 15 business days for formal requests to exercise rights under the LGPD.