agb89 Privacy Policy — Your Data, Explained Clearly

1. "Personal Data" means any information that identifies or can reasonably be used to identify a living individual, whether directly or in combination with other information.
2. "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, and deletion.
3. "Data Controller" means agb89, the entity that determines the purposes and means of processing your Personal Data.
4. "Data Processor" means a third party that processes Personal Data on behalf of agb89 under a written data-processing agreement.
5. "Sensitive Data" means Personal Data revealing racial or ethnic origin, religious beliefs, health information, financial account numbers, or government-issued identity numbers (e.g., Indonesian National ID — KTP number).
6. "Cookie" means a small text file placed on your device by a website to store information about your browsing session or preferences.
7. "Consent" means freely given, specific, informed, and unambiguous agreement to the processing of your Personal Data for a stated purpose.

agb89 is the Data Controller for all Personal Data processed through the agb89 Platform at https://agb89.cam. agb89 is licensed and regulated internationally and operates its data practices in accordance with internationally recognized data protection standards.

For all data protection enquiries, requests to exercise your rights, or questions about this Policy, please contact our dedicated data protection contact at:

agb89 collects the following categories of Personal Data in connection with the provision of its services:

agb89 does not intentionally collect Sensitive Data beyond government-issued identity documents required for KYC compliance. KTP data is used solely for age and identity verification and is not shared with third parties except as required by applicable regulation.

Personal Data is collected through the following channels:

1. Direct submission: Information you provide when completing the registration form, submitting KYC documents, making deposits or withdrawals, contacting customer support, or updating your Account profile.
2. Automated technical collection: Data collected automatically when you visit or interact with the Platform, including cookies, web beacons, session logs, and server access records. See Section 9 for full cookie details.
3. Payment processing partners: Transaction confirmation data, payment method identifiers, and fraud-detection signals provided by our regulated payment processing partners in connection with deposit and withdrawal activity.
4. Identity verification services: Confirmation results (pass / refer / fail) from our third-party KYC and anti-money-laundering screening partners. These partners do not provide the underlying source data to agb89; they provide only the verification outcome.
5. Device and browser data: Technical metadata automatically transmitted by your browser or device when you connect to our servers, including IP address, device fingerprint data, and browser headers.

agb89 processes Personal Data only where a legitimate legal basis exists. The table below sets out the primary purposes for which we process your data and the corresponding legal basis for each:

Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

agb89 does not sell, rent, or trade your Personal Data to any third party for their independent marketing or commercial purposes. We share data only in the following circumstances:

1. Payment processing partners: BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, and LinkAja receive only the data necessary to process your specific transaction (account identifiers, transaction amount, and timestamp). These partners are bound by their own regulatory obligations under Indonesian financial law.
2. KYC and AML service providers: Third-party identity verification and sanctions screening providers receive your identity documents and personal details solely to perform the verification service. Results are returned to agb89; source documents are not retained by these providers beyond their own contractually defined retention windows.
3. Game content providers: Providers such as Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive a pseudonymous player identifier (never your name or financial details) to facilitate game session management and audit trail compliance.
4. IT infrastructure and cloud service providers: Hosting, database, and content delivery partners process Technical and Usage Data as Data Processors under binding data-processing agreements that prohibit any independent use of your data.
5. Regulatory authorities and law enforcement: agb89 will disclose Personal Data to competent government authorities, regulators, or law enforcement agencies where required by applicable law, court order, or regulatory directive — and only to the extent required by that legal obligation.
6. Business transfers: In the event of a merger, acquisition, or sale of all or a material part of agb89's business, your Personal Data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and the acquiring entity's privacy practices at the time of transfer.

agb89's primary data processing infrastructure is located outside Indonesia. When your Personal Data is transferred to servers or service providers located in other countries, agb89 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to internationally recognized data protection principles.

Safeguards we employ for international transfers include:

• Contractual clauses equivalent to standard data protection contractual terms embedded in all Data Processor agreements.
• Limiting transfers to jurisdictions with recognized data protection frameworks or to service providers that have implemented equivalent technical and organizational security measures.
• Data minimization — transferring only the minimum necessary data to complete the specific processing purpose.

agb89 retains Personal Data for the minimum period necessary to fulfill the purpose for which it was collected, and no longer than required by applicable legal or regulatory obligations. The following retention periods apply:

Following the expiry of the applicable retention period, Personal Data is securely deleted or anonymized. Anonymized data (from which you cannot be identified) may be retained indefinitely for aggregated statistical and analytical purposes.

agb89 uses cookies and similar tracking technologies to operate the Platform, improve your experience, and collect aggregate analytics data. The following categories of cookies are in use:

1. Strictly Necessary Cookies: Required for the Platform to function. These enable core features such as session management, login state persistence, and fraud-detection signals. These cookies cannot be disabled without breaking the Platform's core functionality.
2. Performance and Analytics Cookies: Collect aggregated, anonymous data about how visitors navigate the Platform — which pages are most visited, how long sessions last, and where users exit. This data is used solely to improve the Platform.
3. Functional Cookies: Remember your preferences such as language settings, previously selected payment methods, and responsible gaming tool configurations so you do not need to re-enter them each session.
4. Session Identification Cookies: Maintain a secure, encrypted session identifier while you are logged in. These are deleted when you log out or when your browser session ends.

agb89 implements a multi-layered security architecture to protect your Personal Data against unauthorized access, disclosure, alteration, or destruction. Our current measures include:

• Transport Encryption: All data transmitted between your browser and our servers is encrypted using TLS 1.3 with 256-bit AES encryption.
• Data-at-Rest Encryption: Sensitive data fields stored in our databases — including KTP numbers and bank account identifiers — are encrypted at the storage layer using AES-256.
• Access Controls: Personal Data is accessible only to agb89 employees and contractors with a documented, role-based business need. Access is logged and audited regularly.
• Two-Factor Authentication: Available to all Members for Account login. agb89 internal systems require multi-factor authentication for all staff with access to production data.
• Regular Security Audits: agb89's infrastructure and application layer undergo periodic security penetration testing and vulnerability assessments by qualified independent security professionals.
• Incident Response: agb89 maintains a documented data-breach response procedure. In the event of a breach materially affecting your data, we will notify you promptly and take all reasonable steps to contain the incident and prevent recurrence.

No data transmission over the internet or electronic storage system is 100% secure. While we take commercially reasonable steps to protect your data, we cannot guarantee absolute security. We encourage you to protect your Account by using a strong, unique password and enabling two-factor authentication.

Subject to applicable law and the terms of this Policy, you have the following rights with respect to your Personal Data held by agb89:

1. Right of Access: You may request a copy of the Personal Data agb89 holds about you, along with information about how it is being used.
2. Right to Rectification: You may request correction of any inaccurate or incomplete Personal Data held about you. For basic Account details (email, phone number, address), you may update these directly in your Account settings.
3. Right to Erasure ("Right to Be Forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, or where you have withdrawn consent and no other legal basis applies. Note that certain data categories must be retained for defined legal periods (see Section 8) and cannot be deleted until those periods have elapsed.
4. Right to Restrict Processing: You may request that agb89 limit its processing of your data in certain circumstances — for example, while the accuracy of data is being contested.
5. Right to Data Portability: You may request your Account data in a structured, commonly used, machine-readable format (CSV or JSON) for transfer to another service provider, where technically feasible.
6. Right to Object: You may object to processing based on legitimate interests — including direct marketing (see Section 12) — at any time. agb89 will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
7. Right to Withdraw Consent: Where processing is based on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

To exercise any of the above rights, contact us at [email protected] with the subject line "Data Rights Request". We will respond within 30 calendar days. We may ask you to verify your identity before processing your request to protect against unauthorized data access.

agb89 sends promotional communications — including bonus offers, seasonal promotions (such as those tied to Idul Fitri, Ramadhan, or the BRI Liga 1 season), and product updates — only to Members who have actively opted in to receive such communications at the time of registration or via Account settings.

1. You may opt out of all marketing communications at any time by: (a) updating your notification preferences in the Account settings panel; or (b) contacting support at [email protected] with the subject line "Unsubscribe".
2. Opting out of marketing does not affect transactional communications — you will continue to receive Account security alerts, deposit confirmations, withdrawal notifications, and KYC status updates regardless of your marketing preference.
3. Where agb89 sends marketing via third-party messaging platforms (such as messaging apps), any opt-out instructions within those messages must be followed in that channel, in addition to updating your Account settings.

The agb89 Platform is strictly for adults aged 21 and above. We do not knowingly collect Personal Data from individuals under the age of 21. If you are a parent or guardian and believe that a minor has registered on the Platform or provided us with their Personal Data without your consent, please contact us immediately at [email protected].

Upon receiving a verified report of underage registration, agb89 will immediately suspend the relevant Account, delete all associated Personal Data (subject to any overriding legal retention obligations), and return any deposited funds. We take underage access to gambling services extremely seriously and cooperate with any regulatory investigation in this regard.

The agb89 Platform does not contain links to external third-party websites. However, game providers, payment processors, and other service partners whose products are integrated within the Platform maintain their own independent privacy policies. agb89 is not responsible for the data practices of these third parties in contexts outside of their contractual role as Data Processors for agb89.

If you believe you have been directed to an external site from within the agb89 Platform, please report this immediately to our support team, as it may represent an unauthorized modification of your browser or a phishing attempt.

agb89 reviews and updates this Privacy Policy periodically to reflect changes in our data practices, legal obligations, or the services we provide. When material changes are made, we will notify active Members by email and by posting a prominent notice on the Platform homepage at least 7 days before the changes take effect.

The date of the most recent update is displayed at the top of this page. Your continued use of the Platform after the effective date of any updated Policy constitutes your acknowledgment of and agreement to the revised terms. We encourage you to review this Policy each time you visit the Platform.

For all privacy-related enquiries, requests to exercise your data rights, or concerns about how agb89 handles your Personal Data, please contact us using the details below:

If you are not satisfied with our response to a data rights request or privacy complaint, you have the right to escalate the matter to the relevant data protection or privacy authority in your jurisdiction. agb89 cooperates fully with all legitimate regulatory enquiries.