Privacy Policy

1. Definitions

The following terms are used throughout this Privacy Policy and carry the meanings defined below:

• "Personal Data" — any information that identifies or can reasonably identify a natural person, including name, identification number, location data, email address, and online identifiers.
• "Sensitive Data" — a subset of Personal Data that warrants heightened protection, including government-issued identification numbers (Indonesian KTP number, passport number), financial account details, and biometric data.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, use, disclosure, alteration, or deletion.
• "Controller" — the entity that determines the purposes and means of processing Personal Data; in this context, daun83.
• "Processor" — a third party that processes data on behalf of the Controller (e.g., payment gateway providers, KYC verification services).
• "Member" — any individual who has registered an account on the daun83 platform.
• "Cookie" — a small text file stored on a Member's device by the Platform, used to maintain session state, preferences, and analytics.

2. Data We Collect

daun83 collects the following categories of personal and operational data from Members:

2.1 Identity & Contact Information

• Full legal name (as it appears on government-issued ID)
• Date of birth (to verify the 21+ age requirement)
• Indonesian KTP number or passport number
• Residential address (city, province, postal code — Indonesia)
• Email address and mobile phone number
• Profile photograph (when submitted for KYC verification)

2.2 Financial & Payment Data

• Bank account details (account holder name, account number, bank name — BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP)
• E-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja registered phone numbers)
• Deposit and withdrawal transaction history
• Account balance and betting activity records
• Bonus eligibility and redemption history

2.3 Technical & Behavioral Data

• IP address and geolocation data
• Device type, operating system, and browser information
• Session duration and login timestamps
• Pages visited and features accessed within the Platform
• Bet placement patterns (used for fraud detection and responsible gaming monitoring)

2.4 Communication Data

• Customer support chat and email correspondence
• Survey responses and feedback submissions
• Marketing preference settings (opt-in/opt-out status for promotional emails and SMS)

3. How We Collect Data

daun83 collects personal data through the following methods:

• Direct Submission: Information you provide when registering an account, completing KYC verification, initiating deposits or withdrawals, or contacting customer support.
• Automatic Collection: Technical data gathered automatically when you access the Platform, including browser cookies, device fingerprinting, and server access logs.
• Third-Party Verification Services: Identity and document verification data obtained from licensed KYC service providers to confirm the authenticity of submitted documents.
• Payment Processors: Transaction confirmation data relayed by our banking partners (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay) during deposit and withdrawal processing.
• Fraud Prevention Systems: Behavioral and technical signals processed by our anti-fraud infrastructure to detect suspicious activity and protect Members from unauthorized account access.

4. Purpose of Processing

daun83 processes your personal data for the following specific and legitimate purposes:

Purpose	Data Categories Used
Account registration and authentication	Identity, contact, technical data
Age verification and KYC compliance	Identity data, government ID documents
Processing deposits and withdrawals	Financial, identity, and contact data
Bet settlement and gaming services	Account, financial, an d behavioral data
Fraud prevention and security monitoring	Technical, behavioral, and financial data
Responsible gaming monitoring and intervention	Behavioral, financial, and contact data
Customer support and dispute resolution	Identity, communication, and account data
Regulatory reporting and anti-money laundering compliance	Identity, financial, and transaction data
Marketing communications (with consent)	Contact data and marketing preferences
Platform analytics and service improvement	Technical and behavioral data (aggregated)

5. Legal Basis for Processing

daun83 processes your personal data on one or more of the following legal grounds:

• Contractual Necessity: Processing required to perform our obligations under the Member agreement — including account management, payment processing, and bet settlement.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering (AML) obligations, KYC requirements, and regulatory reporting mandates.
• Legitimate Interests: Processing carried out for fraud prevention, platform security, responsible gaming monitoring, and service quality improvement — where such interests do not override your fundamental privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, which requires your explicit opt-in consent. You may withdraw consent at any time by updating your account preferences or contacting support.

6. Data Sharing & Disclosure

6.1 Authorized Third-Party Processors

daun83 shares personal data only with carefully vetted third-party processors under strict data processing agreements. These include:

• Payment service providers — BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, OVO, DANA, GoPay, ShopeePay, and LinkAja — solely for the purpose of processing your deposits and withdrawals.
• KYC and identity verification providers — licensed services that verify the authenticity of government-issued identification documents and confirm Member age.
• Anti-fraud and risk management systems — technology providers that analyze transaction patterns to detect unauthorized access and fraudulent activity.
• Game content providers — Evolution Gaming, Pragmatic Play, Microgaming, and other licensed studio partners, who receive only the minimum data necessary to render and settle game sessions.
• Cloud infrastructure providers — secure hosting and data storage services operating under contractual data protection obligations.

6.2 Legal Disclosure

daun83 may disclose personal data to law enforcement agencies, regulatory authorities, or courts of competent jurisdiction when required to do so by applicable law, court order, or when we determine in good faith that disclosure is necessary to protect the rights, property, or safety of daun83, our Members, or the public.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets, Member personal data may be transferred to the acquiring entity. We will notify affected Members via email prior to any such transfer and provide information about the privacy choices available to them at that time.

6.4 No Sale of Personal Data

daun83 does not sell, rent, lease, or trade your personal data to any third party for marketing, advertising, or commercial purposes. This prohibition applies without exception.

7. Cookies & Tracking Technologies

7.1 What Are Cookies?

Cookies are small text files stored on your device when you visit the daun83 Platform. They enable the site to recognize your browser across sessions, maintain your login state, and remember your preferences. We also use similar tracking technologies including local storage objects and session tokens.

7.2 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function correctly. These include session authentication tokens, CSRF protection tokens, and load-balancing identifiers. These cannot be disabled without breaking core functionality.
• Functional Cookies: Store your preferences such as language settings, odds display format, and preferred payment method to improve your experience across sessions.
• Analytics Cookies: Collect aggregated, anonymized data about how Members navigate the Platform, which pages are visited most frequently, and where technical errors occur. This data informs ongoing service improvements.
• Security Cookies: Used by our fraud-detection systems to identify anomalous login behavior, unusual betting patterns, or signs of account compromise.

7.3 Managing Cookies

You may control non-essential cookies through your browser settings. Most modern browsers allow you to block, delete, or receive notifications when cookies are set. Please note that disabling essential cookies will impair your ability to log in and use core Platform features. Detailed browser-specific cookie management instructions are available in your browser's help documentation.

8. Data Retention

daun83 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, subject to the following guidelines:

• Active Account Data: Retained for the lifetime of your account plus 5 years following closure, to comply with anti-money laundering record-keeping requirements.
• Transaction Records: Financial transaction records are retained for a minimum of 7 years in accordance with international AML standards and applicable regulatory requirements.
• KYC Documents: Identity verification documents are retained for 5 years after account closure or the last transaction date, whichever is later.
• Support Communications: Customer support correspondence is retained for 3 years from the date of the final communication in each ticket.
• Marketing Data: Retained until you withdraw consent or for 2 years of inactivity from your last engagement with a marketing communication, whichever occurs first.
• Technical Logs: Server access logs and security event logs are retained for up to 12 months, after which they are purged or permanently anonymized.

9. Data Security

daun83 implements a comprehensive, multi-layered approach to data security. Our security measures include:

• Encryption in Transit: All data transmitted between Members and our servers is encrypted using TLS 1.3 / 256-bit SSL protocols.
• Encryption at Rest: Sensitive data stored in our databases — including financial information and KYC documents — is encrypted using AES-256 encryption.
• Access Controls: Personal data is accessible only to daun83 employees and contractors with a demonstrated business need. Access is governed by role-based permissions and multi-factor authentication requirements.
• Regular Security Audits: We conduct periodic third-party penetration tests and vulnerability assessments to identify and remediate potential weaknesses in our infrastructure.
• Incident Response Plan: A documented data breach response plan is maintained and tested regularly to ensure rapid detection, containment, and notification in the event of a security incident.
• Employee Training: All daun83 staff with access to Member data receive mandatory data protection training and are bound by confidentiality obligations.

10. Your Data Rights

As a Member of daun83, you hold the following rights regarding your personal data. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request" and proof of identity:

• Right of Access: You may request a copy of the personal data we hold about you. We will provide a structured, readable summary within 30 days of a verified request.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data. Minor corrections (e.g., phone number updates) can be made directly through your account settings.
• Right to Erasure: You may request deletion of your personal data, subject to legal retention obligations. We cannot delete data that we are required by law to retain, but we will delete everything not subject to such obligations.
• Right to Restrict Processing: You may request that we limit the processing of your data in certain circumstances, such as while a dispute about data accuracy is being resolved.
• Right to Data Portability: You may request that we provide your personal data in a structured, machine-readable format (CSV or JSON) for transfer to another service provider.
• Right to Object: You may object to processing based on legitimate interests, including direct marketing. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing emails), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

11. International Data Transfers

daun83 operates internationally, and your personal data may be stored and processed on servers located outside of Indonesia. When we transfer personal data across borders, we ensure that appropriate safeguards are in place, including contractual data protection clauses with receiving entities, and that the receiving jurisdiction provides an adequate level of data protection. We take all reasonable steps to ensure that international transfers comply with applicable privacy laws and that your data receives the same level of protection as it would in Indonesia.

12. Minors & Age Restriction

daun83 services are strictly intended for adults aged 21 years and older. We do not knowingly collect personal data from individuals under the age of 21. If we discover that we have inadvertently collected data from a minor, we will immediately close the associated account, void all transactions, and permanently delete the personal data from our records. If you believe that a minor has registered an account on our Platform, please notify us immediately at [email protected] so we can take prompt action. Parents and guardians are encouraged to utilize parental control software to prevent minors from accessing online gambling platforms.

13. Changes to This Policy

daun83 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or business operations. We will notify Members of material changes via email at least 14 days before the updated policy takes effect. The "Last Updated" date at the top of this document reflects the most recent revision. Your continued use of the Platform after the effective date of any changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this page periodically to stay informed about how we protect your information.

14. Contact & Data Requests

For any questions, concerns, or formal requests relating to this Privacy Policy or the handling of your personal data, please contact the daun83 Data Protection team through the following channels:

• Email: [email protected] — for general privacy inquiries and data rights requests
• Live Chat: Available 24/7 on the Platform for immediate assistance
• Response Timeframe: We aim to acknowledge all privacy-related correspondence within 24 hours and provide a substantive response within 30 days
• Support Hours: Our Indonesian-speaking privacy support staff are available 24/7 (WIB timezone)