Privacy Policy

In this Privacy Policy, the following terms carry the meanings set out below:

• "869zk" — the online gaming platform operated at https://869zk.cam, including all associated services and interfaces.
• "Personal Data" — any information that identifies, or could reasonably be used to identify, a living individual, including name, email address, phone number, financial account details, IP address, and device identifiers.
• "Player" / "You" — any individual who accesses, registers on, or interacts with the 869zk Platform in any capacity.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, alteration, retrieval, use, transmission, restriction, erasure, or destruction.
• "Data Controller" — the entity that determines the purposes and means of Processing Personal Data. 869zk acts as Data Controller in respect of all Personal Data collected through the Platform.
• "Data Processor" — a third party that processes Personal Data on behalf of 869zk under a written contractual agreement, such as KYC verification providers or payment processors.
• "DPO" — the Data Protection Officer appointed by 869zk to oversee privacy compliance and serve as the point of contact for data-related enquiries.
• "Cookies" — small text files placed on your device by the Platform to support functionality, analytics, and personalisation.

869zk collects the following categories of Personal Data, depending on how you interact with the Platform:

2.1 Identity Data

• Full legal name (as it appears on your Indonesian KTP)
• Date of birth
• Nationality and country of residence
• Photograph (selfie submitted during KYC verification)
• Copy of government-issued identity document (KTP)

2.2 Contact Data

• Email address
• Mobile phone number
• Residential address (if requested for enhanced KYC)

2.3 Financial Data

• Bank account details (account holder name, bank name, account number) — used exclusively for processing deposits and withdrawals via BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, Bank Permata, and supported e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja)
• Transaction history (deposits, withdrawals, bet amounts, and associated timestamps)

2.4 Technical and Device Data

• IP address and approximate geolocation derived from IP
• Browser type, version, and language settings
• Operating system and device type
• Session duration and pages visited
• Login timestamps and access logs

2.5 Behavioural and Gaming Data

• Betting and gaming activity records, including game types, stake amounts, win/loss outcomes, and session durations
• Bonus and promotion usage history
• Responsible gaming tool usage (deposit limits set, cool-off periods activated, self-exclusion requests)

2.6 Communications Data

• Records of customer support interactions, including live chat transcripts and email correspondence
• Feedback or survey responses voluntarily submitted by Players

Personal Data is collected through the following methods:

• Direct Provision: You provide data directly to 869zk when you register an Account, submit KYC documents, request a withdrawal, contact customer support, or opt into marketing communications.
• Automated Collection: Technical and behavioural data is collected automatically through cookies, web beacons, and server logs each time you access the Platform.
• Third-Party Verification: During KYC processing, we may receive data from regulated third-party verification providers who confirm the authenticity of your submitted identity documents.
• Payment Processors: When you deposit or withdraw funds, our integrated payment processors share transaction status data with us to enable real-time account crediting and withdrawal processing.

869zk processes your Personal Data for the following specific purposes:

1. Account Management: To create, maintain, and secure your Player Account, including authentication and credential recovery.
2. KYC and Age Verification: To verify your identity, confirm you are at least 21 years of age, and comply with anti-money laundering (AML) and responsible gaming regulations.
3. Payment Processing: To process deposits and withdrawals through Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, Bank Permata) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja).
4. Service Delivery: To enable you to place bets on sports (football, badminton, MotoGP, e-sports), play togel (Indonesia's traditional numbers lottery), access live dealer casino games, and use slot machines.
5. Bonus and Promotion Administration: To manage promotional offers, verify eligibility, track wagering requirements, and prevent bonus abuse.
6. Fraud Prevention and Platform Security: To detect and prevent fraudulent activity, multi-accounting, collusion, money laundering, and other prohibited conduct. This includes monitoring betting patterns and device fingerprints.
7. Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance through our 24/7 Indonesian-speaking support team.
8. Responsible Gaming: To implement self-exclusion, deposit limits, cool-off periods, and reality checks, and to identify Players who may be experiencing problem gambling behaviours.
9. Regulatory Compliance: To meet legal and regulatory obligations, including record-keeping requirements, tax reporting, and responding to lawful requests from authorities.
10. Platform Improvement: To analyse usage patterns, identify technical issues, and improve Platform features, user experience, and performance.
11. Marketing Communications (with consent): To send you promotional offers, newsletters, and personalised recommendations where you have opted in to receive such communications.

869zk processes your Personal Data on one or more of the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our obligations under the Terms & Conditions you accepted when registering your Account, including KYC verification, payment processing, and service delivery.
• Legal Obligation: Processing is required to comply with applicable laws and regulations, including AML, counter-terrorism financing (CTF), tax reporting, and responsible gaming legislation.
• Legitimate Interests: Processing is necessary for 869zk's legitimate interests in preventing fraud, ensuring platform security, protecting other Players, and improving our services, provided such interests do not override your fundamental rights.
• Consent: Where required by law, such as for marketing communications or certain types of cookies, processing is based on your explicit, freely given, informed consent, which may be withdrawn at any time.

869zk does not sell, rent, or trade your Personal Data to third parties for their own marketing purposes. We may share your data with the following categories of recipients only where necessary to deliver our services or comply with legal obligations:

• KYC Verification Providers: Regulated third-party services that confirm the authenticity of identity documents and check against sanctions lists and fraud databases.
• Payment Processors and Banks: Financial institutions and payment gateways that process deposits and withdrawals, including BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, Bank Permata, and e-wallet providers.
• Game Content Providers: Licensed software studios and live dealer operators whose platforms integrate with 869zk. These providers receive only technical session data, not your full identity or financial details.
• Cloud Infrastructure and IT Service Providers: Secure hosting and data storage providers that operate under strict data processing agreements and confidentiality obligations.
• Professional Advisors: Lawyers, accountants, auditors, and consultants who require access to Personal Data to provide professional services to 869zk under confidentiality obligations.
• Regulatory Authorities and Law Enforcement: Government agencies, licensing authorities, and law enforcement bodies where disclosure is required by applicable law, court order, or regulatory instruction, or where necessary to protect the rights, safety, or property of 869zk or others.

869zk retains your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

• Active Accounts: Personal Data associated with active Accounts is retained for the duration of the Account's existence plus any applicable regulatory retention period following Account closure.
• Closed Accounts: After voluntary Account closure, Identity Data and Financial Transaction Data are retained for a minimum of 7 years to comply with AML regulations, tax laws, and legal record-keeping requirements. After this period, data is securely deleted unless retention is required for ongoing legal proceedings.
• Self-Excluded Accounts: Data related to self-excluded Players is retained for the duration of the exclusion period plus 7 years to prevent circumvention of responsible gaming controls and to comply with regulatory obligations.
• Marketing Data: Where you have consented to marketing communications, we retain your contact preferences until you withdraw consent, after which marketing-related data is deleted within 30 days.
• Technical and Log Data: Server logs, IP address records, and device data are typically retained for 12 months for security monitoring and fraud detection purposes, then anonymised or deleted.

You may request early deletion of your data by contacting our DPO, subject to 869zk's legal and regulatory retention obligations.

869zk implements industry-standard technical and organisational measures to protect your Personal Data against unauthorised access, loss, alteration, or disclosure. These measures include:

• SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS protocols.
• Encrypted Data Storage: Personal Data at rest is encrypted using AES-256 encryption standards and stored on secure servers located in ISO 27001-certified data centres.
• Access Controls: Strict role-based access controls ensure that only authorised personnel with a legitimate business need can access Personal Data. All access is logged and audited.
• Multi-Factor Authentication: Critical internal systems require multi-factor authentication (MFA) to prevent unauthorised admin access.
• Regular Security Audits: 869zk conducts quarterly internal security reviews and annual third-party penetration tests to identify and remediate vulnerabilities.
• Incident Response Plan: A documented data breach response procedure is in place. In the event of a breach affecting your Personal Data, we will notify you and relevant authorities within 72 hours as required by applicable law.
• Employee Training: All 869zk staff members undergo mandatory data protection training and are bound by confidentiality agreements.

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 Account login credentials and should notify us immediately if you suspect unauthorised access.

869zk uses cookies and similar tracking technologies to support Platform functionality, analyse usage patterns, and personalise your experience. Cookies are small text files stored on your device when you visit the Platform.

Types of Cookies We Use:

• Essential Cookies: Required for basic Platform operation, including session management, authentication, and security features. These cannot be disabled without breaking core functionality.
• Performance Cookies: Collect anonymous data on how Players interact with the Platform, helping us identify technical issues and improve page load times. Example: Google Analytics (anonymised IP).
• Functional Cookies: Remember your preferences such as language selection, time zone, and display settings to enhance your experience across sessions.
• Fraud Prevention Cookies: Enable device fingerprinting and behavioural analysis to detect suspicious activity, prevent multi-accounting, and protect against fraud.

Managing Cookies:

You can control cookie settings through your browser preferences. Most browsers allow you to block or delete cookies. However, disabling essential cookies will prevent you from using key Platform features, including logging in and placing bets. Performance and functional cookies can typically be disabled without affecting core functionality.

For more information on cookie management, consult your browser's help documentation. Clearing cookies will log you out and reset your preferences.

You hold the following rights in relation to your Personal Data under internationally recognised data protection principles:

• Right of Access: You may request a copy of all Personal Data 869zk holds about you, including details of how it is processed and with whom it has been shared.
• Right to Rectification: If any Personal Data we hold is inaccurate or incomplete, you may request that it be corrected or updated.
• Right to Erasure (Right to be Forgotten): You may request deletion of your Personal Data, subject to our legal and regulatory retention obligations (e.g., AML requirements). Where deletion is not possible due to legal constraints, we will restrict processing instead.
• Right to Restriction of Processing: You may request that we limit how we use your Personal Data in certain circumstances, such as while a dispute over data accuracy is being resolved.
• Right to Data Portability: You may request a machine-readable copy of your Personal Data to transfer to another service provider.
• Right to Object: You may object to processing based on legitimate interests. Where we cannot demonstrate compelling legitimate grounds that override your interests, we will cease processing.
• Right to Withdraw Consent: Where processing is based on consent (e.g., marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.
• Right to Lodge a Complaint: If you believe 869zk has violated data protection laws, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.

To exercise any of these rights, contact our Data Protection Officer using the details provided in Section 15. We will respond to all legitimate requests within 30 days. Identity verification may be required to prevent unauthorised data disclosure.

869zk is strictly a 21+ platform. We do not knowingly collect Personal Data from individuals under the age of 21. Age verification is mandatory during the KYC process, and any Account found to belong to a minor will be immediately suspended, all funds returned where possible, and the Account permanently closed.

If you are a parent or guardian and believe your child under 21 has provided Personal Data to 869zk, contact our DPO immediately. We will take prompt steps to delete such data and prevent further access.

The 869zk Platform may contain links to third-party websites or services, such as payment gateways or game content providers. This Privacy Policy applies only to Personal Data collected directly by 869zk. We are not responsible for the privacy practices of third-party sites.

When you leave the 869zk Platform via an external link, you are subject to the privacy policy of the destination site. We encourage you to review the privacy policies of any third-party services you use.

869zk operates as an internationally licensed gaming platform. Your Personal Data may be transferred to, stored in, and processed in jurisdictions outside Indonesia where our servers, service providers, or regulatory licensing authorities are located.

Where Personal Data is transferred internationally, 869zk ensures appropriate safeguards are in place, including:

• Standard contractual clauses approved by recognised data protection authorities
• Selection of service providers in jurisdictions with adequate data protection laws
• Binding corporate rules and data processing agreements with all international processors

By using the 869zk Platform, you acknowledge and consent to such international transfers under these safeguards.

869zk reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, legal requirements, or business operations. When material changes are made, we will notify registered Players via email or an in-platform notification at least 14 days before the changes take effect.

The effective date at the top of this Policy reflects the most recent version. Continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree to the changes, you may close your Account as described in the Terms & Conditions.

We encourage you to review this Policy periodically to stay informed about how we protect your Personal Data.

If you have any questions, concerns, or requests regarding this Privacy Policy or how 869zk handles your Personal Data, please contact our Data Protection Officer:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line: Please use "Privacy Enquiry – [Your Account Username]" for priority handling
• Response Time: All privacy-related enquiries are responded to within 48 hours during business days (Monday to Friday, 08:00–18:00 WIB)

To exercise your data rights (access, rectification, erasure, restriction, portability, or objection), include your full name, registered email address, and a clear description of your request. Identity verification will be required before we process any request that involves accessing or modifying your Personal Data.