8839com Privacy Policy – LGPD

1 Introduction and Data Controller

This Privacy Policy describes how the 8839com collects, uses, stores, shares, and protects the personal data of users who access the platform available at 8839com.best, as well as any official brand application. This policy is an integral part of the Terms and Conditions of the 8839com and should be read together with them.

The 8839com acts as the data controller for its users' personal data, pursuant to General Personal Data Protection Law – LGPD (Law No. 13.709/2018). As the data controller, the 8839com is responsible for decisions regarding data processing and for ensuring that such processing complies with current Brazilian legislation.

When you create an account on 8839com, by making a Pix deposit, or by using any feature on the platform, the user confirms they have read and understood this Privacy Policy and consents to the processing of their personal data as described herein. Consent may be withdrawn at any time, as detailed in the user rights section.

If you have any questions about this policy or how your data is handled, please reach out at: suporte@8839com.best.

2 Personal Data We Collect

2.1 Data Provided by the User at Registration

When you create an account on 8839com, we request the following information:

• Full name — for identification of the account holder;
• CPF — for identity verification, regulatory compliance, and account linking;
• Email address — for communication, registration confirmation, and account access recovery;
• Mobile number — for two-factor authentication and account-related communications;
• Date of birth — to verify the minimum age requirement of 18 years set by the platform;
• Residential address — for location verification and regulatory compliance.

2.2 Financial and Transaction Data

To process deposits via Pix, credit card, bank slip, PicPay, Mercado Pago, TED transfers, and withdrawals, the 8839com collects:

• Pix Key (CPF, phone number, email, or random key) linked to the user's account;
• Banking details for TED processing — bank name, branch, account number, and account holder's CPF;
• Credit or debit card data — number, expiry date, and CVV, processed with encryption and never stored in plain text;
• Transaction history — deposits, withdrawals, bets, and winnings recorded on the platform.

The 8839com does not store full card details on its own servers. Card payment processing is handled by PCI-DSS certified payment providers.

2.3 Usage & Browsing Data

As you browse the platform, the 8839com automatically collects:

• IP address and approximate location data;
• Device type, operating system, and browser used;
• Pages visited, session duration, and features used;
• Cookie data and session identifiers (detailed in Section 8).

2.4 Identity Verification Data (KYC)

For withdrawals above certain limits or during account review situations, the 8839com may request identity verification documents, including a copy of your RG, CNH, or passport, and proof of address. These documents are collected exclusively for regulatory compliance and anti-money laundering purposes, and are not shared with third parties beyond those required by law.

3 How We Use Your Data

The 8839com uses the collected data for the following purposes, all with an explicit legal basis under the LGPD:

• Account operation: creation, maintenance, and management of the user's account on the platform, including authentication and access recovery;
• Transaction processing: deposits via Pix, withdrawals, sports betting and casino game processing, and financial history records;
• Identity verification and fraud prevention: verifying account holder identity, detecting multiple accounts, and preventing illicit activities such as money laundering;
• Communication with the user: sending transaction confirmations, security notifications, account updates, and — with consent — promotional communications about new games, sporting events such as the Copa do Brasil or UFC, and personalized offers;
• Experience personalization: personalization of displayed content based on betting preferences — football, volleyball, MMA, slots, crash games — and usage history;
• Compliance with legal obligations: compliance with the LGPD, tax legislation, anti-money laundering regulations, and any determinations issued by competent authorities;
• Platform improvement: analysis of aggregated and anonymized usage data to improve features, fix issues, and develop new functionality.

The 8839com does not use user data to build profiles for sale to third parties, for off-platform advertising without explicit consent, or for any purpose not disclosed in this policy.

4 Legal Basis for Data Processing

All personal data processing carried out by the 8839com is grounded in one of the legal bases provided under the LGPD:

• Consent (art. 7, I): provided by the user at registration and for marketing communications. Can be withdrawn at any time;
• Contract performance (art. 7, V): required to operate the account, process Pix deposits, record bets, and carry out withdrawals — without this data, the service cannot be provided;
• Compliance with a legal obligation (art. 7º, II): user identification, anti-money laundering, tax compliance, and adherence to judicial or administrative orders;
• Legitimate interest (art. 7, IX): fraud prevention, platform security, suspicious behavior analysis, and service improvement — always proportionate and respectful of user rights.

Where processing is based on consent, the 8839com will ensure that such consent is freely given, informed, unambiguous, and recorded. Revoking consent for non-essential purposes does not affect the continuity of services.

5 Data Sharing with Third Parties

The 8839com does not sell users' personal data. Data sharing occurs only in the situations listed below, with partners who take on confidentiality obligations consistent with this policy and with the LGPD:

5.1 Payment Processors

To process deposits and withdrawals via Pix, credit card, bank slip, PicPay, Mercado Pago, and TED, the 8839com shares only the financial data strictly necessary with the institutions and intermediaries responsible for processing. These partners are contractually required to use the data solely for that purpose.

5.2 Casino Game Providers

For the operation of live casino games, slots, and crash games, providers such as Pragmatic Play, Evolution Gaming, NetEnt, and Play'n GO may receive user session identifiers required for the technical functioning of the games. This data is minimal and does not include complete financial information.

5.3 Authorities and Legal Obligations

The 8839com may share data with law enforcement, judicial, tax, or regulatory authorities when required by law, court order, or applicable regulatory obligation. In such cases, the 8839com will share only the data strictly requested, limited to what the law requires.

5.4 Identity Verification (KYC)

For identity verification processes, documents provided by the user may be reviewed by partners specialized in KYC, subject to confidentiality obligations and the same data protection standards applied to the 8839com.

6 Data Retention and Deletion

6.1 Retention Period

The 8839com retains users' personal data for as long as necessary to fulfill the purposes described in this policy. General retention periods are:

• Active account data: retained for the entire period the account remains active;
• Financial transaction history: held by 5 years after the last transaction, in accordance with tax and anti-money laundering obligations;
• Identity verification documents (KYC): retained for 5 years after account closure or as required by law;
• Browsing and usage data: anonymized after 12 months or deleted upon the user's request.

6.2 Data Deletion

After account closure and once the applicable legal retention periods have been met, the 8839com carries out the permanent deletion or anonymization of personal data. Users may request the early deletion of non-essential data — such as browsing preferences and marketing data — at any time, without needing to close their account.

7 Information Security

The 8839com implements technical and organizational measures to protect users' personal data against unauthorized access, loss, alteration, or destruction. Key measures in place include:

• SSL/TLS Encryption: all communications between the user's device and the servers of the 8839com are protected by end-to-end encryption;
• Two-factor authentication (2FA): available to all users who want an extra layer of protection when accessing their account;
• Secure storage: passwords are stored using cryptographic hashing; card data is never stored in plain text on the servers of the 8839com;
• Internal access control: only employees with a legitimate need have access to users' personal data, with full tracking of all queries;
• Security monitoring: intrusion detection systems and continuous monitoring to identify and respond to unauthorized access attempts;
• Periodic security testing: regular audits and penetration testing to identify and remediate vulnerabilities.

In the event of a security incident that may affect users' personal data, the 8839com will notify the National Data Protection Authority (ANPD) and affected users within the timeframes set out by the LGPD, providing details about the nature of the incident and the measures taken.

8 Cookies and Tracking Technologies

8.1 What Are Cookies

Cookies are small text files stored on the user's device when they access the platform. The 8839com uses cookies to ensure the platform functions correctly, personalize your experience, and analyze aggregated usage patterns.

8.2 Types of Cookies Used

8.3 How to Manage Cookies

Users can manage cookie preferences through their browser or device settings — refusing or deleting non-essential cookies. Refusing essential cookies may affect platform functionality, including login and the Pix deposit process. Marketing cookies can be refused without impacting access to the main features of the 8839com.

9 Your Rights as a Data Subject (LGPD)

The LGPD grants personal data subjects a set of rights that the 8839com is fully committed to upholding. You may exercise any of them at any time by emailing suporte@8839com.best:

• Access: request a copy of all personal data that 8839com holds about you;
• Correction: update incomplete, inaccurate, or outdated information in your account;
• Anonymization or blocking: request the anonymization of unnecessary data or the blocking of data processed in violation of the LGPD;
• Portability: receive your data in a structured format for transfer to another service provider, where technically feasible;
• Deletion: request the deletion of data processed on the basis of consent — except for data that must be retained due to a legal obligation;
• Consent withdrawal: withdraw at any time any consent given for non-essential purposes, such as marketing communications;
• Information about sharing: obtain information about which entities the 8839com shared or may have shared your data;
• Objection: object to data processing carried out on the basis of legitimate interest when it disproportionately impacts your rights.

The 8839com will respond to data subject rights requests within 15 business days from the date of receipt. In more complex cases requiring additional identity verification, the deadline may be extended with prior notice to the requester.

10 Minors' Data

The 8839com is a platform intended exclusively for individuals aged 18 years of age or older. The platform does not intentionally collect personal data from users under 18.

Should the 8839com identifies that data from a minor was inadvertently collected, the account will be closed immediately and the data deleted as soon as possible, subject to minimum legal retention obligations.

If you believe a person under 18 has created an account on 8839com, please contact us immediately at suporte@8839com.best so the appropriate steps can be taken as a priority.

11 International Data Transfer

Some of the casino game providers partnered with 8839com — such as Pragmatic Play, Evolution Gaming, NetEnt, and Play'n GO — have servers located outside Brazil. To the extent that session data is processed on those servers to enable game operation, this constitutes an international data transfer under the LGPD.

The 8839com ensures that all international data transfers are made to countries or organizations that provide a level of protection compatible with the LGPD, or on the basis of standard contractual clauses that safeguard the rights of Brazilian data subjects. No international transfer includes users' complete financial data or identity documents.

12 Changes to this Privacy Policy

The 8839com may update this Privacy Policy periodically to reflect changes in data processing practices, applicable law, or the services offered. Material changes will be communicated via the registered email address and through a prominent notice on the platform at least 7 days in advance before they take effect.

The date of the last update is always displayed at the top of this page. Continued use of the platform after the effective date of any changes constitutes acceptance of the updated version of this policy. If you do not agree with the changes, you may close your account before the effective date and request data deletion as outlined in section 9.

13 Contact, DPO & Privacy Channel

For any questions, requests, or complaints related to the processing of personal data by the 8839com, reach out through the channels below:

• Privacy email: suporte@8839com.best (subject: "Privacy – LGPD")
• Live chat: available 24/7 on the 8839com.best platform, in Portuguese
• Response time: up to 15 business days for data subject rights requests

The 8839com maintains a Data Protection Officer (DPO) responsible for overseeing the platform's privacy practices, handling data subject requests, and serving as a liaison between users, the 8839com and the National Data Protection Authority (ANPD). The DPO can be reached at the same email address indicated above, with "DPO" in the subject line.

If you feel that your rights as a data subject have not been properly addressed by the 8839com, you have the right to file a complaint directly with the National Data Protection Authority (ANPD), through the authority's official channels.