Privacy Policy

Section 1 Introduction

ink789 is committed to safeguarding the privacy of our users and complying with applicable data protection laws and regulations. This Privacy Policy applies to all personal data collected through the ink789 website, mobile-optimized interface, and any related services accessible at ink789.cam and its subdomains.

This policy should be read in conjunction with our Terms & Conditions, which govern the use of our platform and services. Where there is a conflict between this Privacy Policy and the Terms & Conditions, the more specific provision shall prevail.

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. Material changes will be communicated to registered users via email. Your continued use of the platform following notification of changes constitutes acceptance of the revised policy.

Section 2 Data Controller

For the purposes of applicable data protection legislation, the data controller responsible for your personal information is:

As the data controller, ink789 determines the purposes and means of processing your personal data. If you have any questions, concerns, or requests regarding the processing of your personal information, please contact us using the details provided in Section 14 of this policy.

Section 3 Information We Collect

ink789 collects several categories of personal information to provide our services, verify your identity, process transactions, and comply with legal obligations. The types of data we collect include:

3.1 Account Registration Data

When you create an ink789 account, we collect the following information:

• Full legal name (as it appears on government-issued ID)
• Date of birth (to verify you meet the 21+ age requirement)
• Residential address (street address, city, postal code)
• Email address (for account notifications and communications)
• Mobile phone number (for account security and verification purposes)
• Username and password (encrypted and stored securely)
• Preferred language and currency (Indonesian Rupiah / IDR)

3.2 Identity Verification (KYC) Data

To comply with anti-money laundering regulations and responsible gaming requirements, we may request:

• Government-issued identity documents: Indonesian National Identity Card (KTP/NIK), passport, or driver's licence (SIM)
• Proof of address: recent utility bill, bank statement, or official correspondence (dated within 90 days)
• Facial verification: photograph or selfie for identity matching purposes
• Source of funds documentation (for high-value transactions or where regulatory compliance requires)

3.3 Financial Transaction Data

We collect information related to deposits, withdrawals, and wagers, including:

• Payment method details: bank account names and partial account numbers (last 4 digits), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja)
• Transaction amounts, dates, times, and currency
• Transaction history and account balance records
• Bonus and promotional credit usage

We do not store full credit card numbers or CVV codes. Payment processing is handled by certified third-party payment processors who maintain PCI-DSS compliance.

3.4 Gameplay and Betting Data

We automatically collect data related to your use of our platform, including:

• Betting history: wagers placed, markets selected, stake amounts, odds, outcomes, winnings, and losses
• Game session data: login/logout times, session duration, games played, game outcomes
• Account activity logs: changes to account settings, limit adjustments, self-exclusion requests

3.5 Technical and Device Data

When you access ink789, we automatically collect technical information, including:

• IP address and geolocation data (to verify your location and detect prohibited territories)
• Device type, operating system, browser type and version
• Screen resolution, time zone settings, language preferences
• Referring URLs, pages visited, click paths, navigation patterns
• Cookies and similar tracking technologies (see Section 8)

3.6 Communications Data

We retain records of communications between you and ink789, including:

• Live chat transcripts with customer support agents
• Email correspondence sent to or received from [email protected]
• Feedback forms, survey responses, and complaint submissions

Section 4 How We Use Your Data

ink789 processes your personal information for the following purposes:

4.1 Service Provision

• To create and maintain your account
• To process deposits, withdrawals, and wager settlements
• To provide access to sports betting, casino games, togel markets, and other gaming products
• To apply bonuses, promotions, and loyalty rewards
• To provide customer support and respond to inquiries

4.2 Identity Verification and Compliance

• To verify your identity and age (21+ requirement)
• To comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations
• To detect and prevent fraudulent activity, account abuse, and prohibited conduct
• To enforce our Terms & Conditions and prevent terms violations

4.3 Responsible Gaming

• To monitor gameplay patterns for signs of problem gambling behaviour
• To enforce deposit limits, loss limits, session timers, and reality checks
• To process self-exclusion requests and cool-off periods
• To provide intervention and support when concerning behaviour is detected

4.4 Marketing and Communications

• To send promotional offers, bonus notifications, and product updates (where you have opted in)
• To personalize marketing content based on your preferences and gameplay history
• To send transactional notifications: deposit confirmations, withdrawal updates, account alerts

You may opt out of marketing communications at any time by adjusting your preferences in your account dashboard or by clicking "unsubscribe" in any promotional email.

4.5 Platform Improvement

• To analyze user behaviour and optimize platform performance
• To conduct A/B testing and product development research
• To improve game offerings, user interface, and overall player experience

4.6 Legal Obligations

• To respond to lawful requests from government authorities, regulators, or law enforcement
• To comply with court orders, subpoenas, or other legal processes
• To cooperate with tax authorities where required by Indonesian or international law

Section 5 Legal Basis for Processing

ink789 processes your personal data based on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contract with you (Terms & Conditions) and to provide the services you have requested.
• Legal Obligation: Processing is required to comply with applicable laws, including anti-money laundering regulations, age verification requirements, and tax reporting obligations.
• Legitimate Interests: Processing is necessary for our legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement — provided such interests are not overridden by your fundamental rights.
• Consent: Where we rely on your consent (e.g., for marketing communications), you have the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

Section 6 Data Sharing & Disclosure

ink789 does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your data with the following categories of recipients under strict confidentiality obligations:

6.1 Service Providers

We engage trusted third-party service providers to support our operations, including:

• Payment processors (banks, e-wallet providers, payment gateways) — to process deposits and withdrawals
• Identity verification services — to perform KYC checks and age verification
• Cloud hosting providers — to store data securely on encrypted servers
• Customer support platforms — to manage live chat and email ticket systems
• Game studio partners (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft) — to provide gaming content

All service providers are contractually bound to use your data only for the specific purposes for which it was disclosed and to maintain appropriate security measures.

6.2 Legal and Regulatory Authorities

We may disclose your information to government agencies, regulators, law enforcement, or courts where required by law or where we reasonably believe disclosure is necessary to:

• Comply with a legal obligation or court order
• Investigate or prevent fraud, illegal activity, or security threats
• Enforce our Terms & Conditions or protect the rights and safety of ink789, our users, or the public

6.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections outlined in this policy.

Section 7 Data Security

ink789 employs industry-standard technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. Our security controls include:

• Encryption: All data transmitted between your device and our servers is protected by 256-bit SSL/TLS encryption. Sensitive data at rest (passwords, payment details, KYC documents) is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized personnel only, based on role-based permissions and the principle of least privilege.
• Secure Infrastructure: Our platform is hosted on secure, geographically distributed cloud infrastructure with redundant backups, intrusion detection systems, and 24/7 monitoring.
• Regular Audits: We conduct regular security audits, vulnerability assessments, and penetration testing to identify and address potential weaknesses.
• Incident Response: We maintain a formal data breach response plan. In the event of a breach affecting your personal data, we will notify you and relevant authorities in accordance with applicable law.

While we implement robust security measures, no method of transmission over the internet or electronic storage is 100% secure. You are responsible for maintaining the confidentiality of your login credentials and for any activity conducted through your account.

Section 8 Cookies & Tracking Technologies

ink789 uses cookies, web beacons, and similar tracking technologies to enhance your experience, analyze platform usage, and deliver personalized content. Cookies are small text files stored on your device that help us recognize you on subsequent visits.

Types of Cookies We Use:

• Essential Cookies: Required for the platform to function properly (account login, session management, security).
• Performance Cookies: Collect anonymous data on how users interact with the platform to improve performance and user experience.
• Functional Cookies: Remember your preferences (language, currency, display settings) to provide a personalized experience.
• Marketing Cookies: Track your activity across sessions to deliver relevant promotional offers and measure campaign effectiveness.

Cookie Management:

You can control cookie settings through your browser preferences. Most browsers allow you to block or delete cookies. However, disabling essential cookies may impair platform functionality, including your ability to log in or place wagers.

To opt out of third-party tracking cookies used for analytics and advertising, you can adjust your browser settings or use opt-out tools provided by advertising networks.

Section 9 Data Retention

ink789 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Retention periods vary by data category:

• Account Data: Retained for the duration of your active account, plus an additional period after account closure as required by financial regulations and anti-money laundering laws (typically 5-7 years).
• Transaction Records: Retained for a minimum of 7 years to comply with financial record-keeping requirements.
• KYC Documents: Retained for the duration of your account plus 5 years post-closure, as required by identity verification and AML regulations.
• Marketing Data: Retained until you withdraw consent or request deletion, whichever comes first.
• Gameplay Logs: Retained for 12 months for operational and responsible gaming monitoring purposes, then archived or anonymized.

After the applicable retention period expires, personal data is securely deleted or anonymized such that it can no longer be attributed to you.

Section 10 Your Privacy Rights

Subject to applicable law, you have the following rights regarding your personal data:

• Right of Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete data.
• Right to Erasure ("Right to be Forgotten"): Request deletion of your data where we no longer have a legitimate reason to retain it, subject to legal retention obligations.
• Right to Restrict Processing: Request that we limit how we use your data in certain circumstances.
• Right to Data Portability: Request a copy of your data in a structured, commonly used format for transfer to another service provider.
• Right to Object: Object to processing based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, withdraw your consent at any time.

To exercise any of these rights, please contact us at [email protected] with your account details and a description of your request. We will respond within 30 days of receipt. We may request additional information to verify your identity before processing your request.

Section 11 International Data Transfers

ink789 operates internationally and may transfer your personal data to servers located outside of Indonesia, including jurisdictions that may not provide the same level of data protection as Indonesian law. Where we transfer data internationally, we implement appropriate safeguards, including:

• Relying on adequacy decisions by Indonesian or international data protection authorities
• Implementing standard contractual clauses approved by data protection regulators
• Ensuring service providers maintain equivalent data protection standards

By using ink789, you acknowledge and consent to the international transfer of your personal data in accordance with this policy.

Section 12 Children's Privacy

ink789 is strictly an adult-only platform. We do not knowingly collect personal information from individuals under the age of 21. If we become aware that we have inadvertently collected data from a minor, we will take immediate steps to delete such information and terminate the associated account.

If you are a parent or guardian and believe your child has provided personal information to ink789, please contact us immediately at [email protected].

Section 13 Changes to This Privacy Policy

ink789 reserves the right to modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or operational needs. The revised policy will be effective immediately upon posting to the platform and will be marked with a new "Last Updated" date.

Material changes that significantly affect your privacy rights will be communicated to registered users via email to the address on file. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

Continued use of the platform following the posting of a revised Privacy Policy constitutes your acceptance of the changes.

Section 14 Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or how ink789 handles your personal data, please contact us:

• Email: [email protected]
• Subject Line: "Privacy Inquiry" or "Data Protection Request"
• Live Chat: Available 24/7 from your account dashboard (for registered users)

We aim to respond to all privacy-related inquiries within 30 days. For urgent matters involving data breaches or unauthorized access, please mark your communication as "URGENT" in the subject line.