Privacy Policy

Introduction

This Privacy Policy ("Policy") explains how 88ku ("we", "us", "our", or the "Platform") collects, processes, stores, and protects the personal information of users ("you", "your", or the "Player") who access and use the services available at https://88ku.cam (the "Site").

88ku is operated by a company licensed under international gaming regulations and is committed to handling all personal data responsibly, transparently, and in accordance with applicable data protection laws. Our primary market is the Republic of Indonesia, and our data practices reflect the privacy expectations of Indonesian players alongside internationally recognised best practices.

By creating an account, accessing the Site, or using any of the Services (including sports betting, live casino, slot games, togel (Indonesia's traditional numbers lottery), and sabung ayam (cockfighting) streams), you acknowledge that you have read and understood this Policy. If you do not agree with how we process your personal data, you should immediately cease using the Services.

This Policy should be read together with our Terms & Conditions and our Responsible Gaming Policy, both of which form part of your agreement with 88ku.

1. Definitions

For the purposes of this Privacy Policy, the following terms are defined as follows:

• "Personal Data" — Any information that can directly or indirectly identify a natural person, including but not limited to name, date of birth, national identity number (NIK), email address, phone number, IP address, payment details, and location data.
• "Processing" — Any operation performed on personal data, including collection, storage, use, disclosure, transfer, alteration, or deletion.
• "Data Controller" — 88ku, which determines the purposes and means of processing your personal data.
• "Data Processor" — Any third party engaged by 88ku to process personal data on our behalf (e.g., payment providers, cloud infrastructure providers, identity verification services).
• "Consent" — A freely given, specific, informed, and unambiguous indication of your agreement to the processing of your personal data.
• "KYC" — Know Your Customer — the identity verification process used to confirm your identity, age, and residency as required by anti-money laundering (AML) regulations.
• "Cookie" — A small data file stored on your device by a website to remember information about your session, preferences, or browsing activity.

2. Personal Data We Collect

We collect personal data in the following circumstances and categories:

2.1 Data You Provide Directly

When you register an account, complete KYC verification, or interact with customer support, you may provide:

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued ID details (e-KTP number, passport number).
• Contact Data: Email address, mobile phone number, and residential address in Indonesia.
• Financial Data: Bank account details (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI), e-wallet account details (OVO, DANA, GoPay, ShopeePay, LinkAja), and transaction records.
• Verification Documents: Scanned copies or photographs of your e-KTP, passport, proof of address documents, and bank statements submitted during KYC.
• Communications: Records of your interactions with our customer support team, including live chat transcripts, email correspondence, and support ticket content.

2.2 Data We Collect Automatically

When you access the Site or use the Services, we automatically collect certain technical information:

• Device Data: IP address, device type, operating system, browser type and version, screen resolution, and unique device identifiers.
• Usage Data: Pages visited, time spent on each page, game sessions initiated, betting history, click patterns, and navigation paths through the Site.
• Location Data: Approximate geographic location derived from your IP address (city and country level; we do not collect precise GPS coordinates).
• Session Data: Login times, logout times, session duration, and authentication events.

2.3 Data We Collect from Third Parties

We may receive personal data from the following third-party sources:

• Payment Processors: Transaction confirmation details and fraud risk scores from BCA, BRI, BNI, Mandiri, and e-wallet providers to verify deposits and withdrawals.
• Identity Verification Services: Confirmation of identity document authenticity from third-party KYC providers.
• Fraud Prevention Services: Risk flags, known fraud patterns, and sanctions list data from compliance databases.

3. How We Use Your Personal Data

88ku processes your personal data only for clearly defined, legitimate purposes. We do not engage in speculative data mining or use your information in ways inconsistent with the purposes disclosed below.

3.1 Account Management and Service Delivery

• Creating, maintaining, and securing your 88ku account.
• Processing deposits and withdrawals via your nominated Indonesian bank or e-wallet.
• Providing access to betting markets, casino games, slots, togel, and all other Services.
• Delivering personalised game recommendations and promotional offers based on your activity and preferences.
• Responding to customer support enquiries, complaints, and dispute resolutions.

3.2 Identity Verification and Regulatory Compliance

• Verifying that you are at least 21 years of age and a resident of Indonesia, as required by our eligibility criteria.
• Completing KYC procedures to satisfy anti-money laundering (AML) and counter-terrorism financing (CTF) obligations.
• Screening your identity against international sanctions lists and politically exposed persons (PEP) databases.
• Detecting, investigating, and preventing fraudulent activity, account takeovers, and prohibited conduct.
• Maintaining transaction records and audit trails as required by applicable regulations.

3.3 Responsible Gaming

• Monitoring your betting patterns to identify signs of problematic gambling behaviour.
• Enforcing self-imposed deposit limits, session time limits, and self-exclusion requests.
• Sending responsible gaming reminders and information about support resources when appropriate.

3.4 Platform Security and Fraud Prevention

• Detecting and preventing cheating, collusion, bonus abuse, and multi-accounting.
• Monitoring for automated betting activity (bots) and other prohibited technical behaviour.
• Protecting the integrity of betting markets and game outcomes.
• Maintaining server security logs and intrusion detection records.

3.5 Platform Improvement and Analytics

• Analysing aggregated, anonymised usage data to improve Site performance, navigation, and game offering.
• Conducting A/B testing of new features and interface designs.
• Measuring the effectiveness of promotional campaigns and bonus structures.

3.6 Marketing Communications

With your consent, we may send you promotional emails, SMS messages, or in-platform notifications about new games, upcoming sporting events (including BRI Liga 1 fixtures, EPL matches, and badminton tournaments), seasonal promotions (such as Idul Fitri or Ramadhan special offers), and bonus opportunities. You may withdraw your consent to marketing communications at any time by updating your account preferences or contacting support at [email protected]. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

4. Legal Basis for Processing

We process your personal data on the following legal grounds:

• Contractual Necessity: Processing required to fulfil our obligations under the Terms & Conditions you agreed to when registering your account — including account creation, transaction processing, and service delivery.
• Legal Obligation: Processing required to comply with applicable laws, including AML/CTF regulations, age verification requirements, and regulatory reporting obligations.
• Legitimate Interests: Processing carried out to pursue our legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and general business analytics — provided these interests do not override your fundamental privacy rights.
• Consent: Processing based on your explicit, freely given consent — specifically for marketing communications and optional personalisation features. You may withdraw consent at any time without penalty to your core account access.

5. Data Sharing and Disclosure

88ku does not sell, rent, or trade your personal data to any third party for their own marketing purposes. We share personal data only in the following limited and controlled circumstances:

5.1 Service Providers (Data Processors)

We engage trusted third-party service providers who process data strictly on our behalf and under our instructions, including:

• Payment processors and banking partners — including BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, OVO, DANA, GoPay, ShopeePay, and LinkAja — for processing deposits and withdrawals.
• Identity verification and KYC providers — for authenticating government-issued ID documents and performing age verification checks.
• Cloud infrastructure and hosting providers — who store platform data on secure, encrypted servers.
• Fraud detection and security firms — who provide risk scoring, anomaly detection, and sanctions screening services.
• Game software providers — such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft — who may receive anonymised session data to support game functionality and fairness auditing.

All third-party service providers are contractually required to maintain confidentiality, implement appropriate security measures, and use your data only for the specific purposes for which it was shared.

5.2 Regulatory and Law Enforcement Authorities

We may disclose personal data to government authorities, law enforcement agencies, financial intelligence units, or courts if required to do so by applicable law, regulatory directive, or valid legal process. We will always assess such requests carefully and disclose only the minimum data required to satisfy the obligation.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of 88ku's business, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify you of any such transfer and ensure that the acquiring party is bound by privacy obligations no less protective than those set out in this Policy.

5.4 With Your Explicit Consent

In circumstances not covered by the categories above, we will share your data with third parties only after obtaining your explicit, informed consent for that specific purpose.

6. Cookies and Tracking Technologies

88ku uses cookies and similar tracking technologies to operate the Site, improve your experience, and gather analytical data. A cookie is a small text file placed on your device when you visit a website. Cookies do not contain executable code and cannot access other files on your device.

6.1 Types of Cookies We Use

6.2 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can configure your browser to block all cookies, accept only certain cookies, or notify you when a cookie is set. Please note that disabling strictly necessary cookies may prevent you from logging in or completing transactions on the 88ku platform. Analytics and functional cookies can be disabled without affecting core account functionality.

7. Data Security

88ku takes the security of your personal data extremely seriously. We implement a comprehensive set of technical and organisational measures to protect your information against unauthorised access, accidental loss, destruction, alteration, or disclosure.

7.1 Technical Safeguards

• TLS 1.3 Encryption: All data transmitted between your device and our servers is encrypted using Transport Layer Security (TLS) version 1.3, ensuring that data in transit cannot be intercepted or read by unauthorised parties.
• AES-256 Encryption at Rest: Sensitive data stored in our databases — including identity documents, financial data, and authentication credentials — is encrypted at rest using AES-256 encryption.
• Multi-Factor Authentication (MFA): We offer MFA for account login and require it for high-value withdrawal requests, significantly reducing the risk of unauthorised account access.
• Firewalls and Intrusion Detection: Our infrastructure is protected by enterprise-grade firewalls and 24/7 intrusion detection systems that flag and respond to suspicious network activity in real-time.
• Regular Penetration Testing: We commission independent security firms to conduct regular penetration tests and vulnerability assessments of our platform.

7.2 Organisational Safeguards

• Access to personal data is restricted to authorised 88ku staff on a strict need-to-know basis.
• All staff who handle personal data are trained in data protection principles and are bound by confidentiality obligations.
• We maintain an incident response plan that includes procedures for detecting, containing, and notifying affected individuals of data breaches within the timeframes required by applicable law.

8. Data Retention

We retain your personal data only for as long as is necessary to fulfil the purposes described in this Policy, or as required by applicable law. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data is securely and irreversibly deleted or anonymised so that it can no longer be associated with any individual. Where anonymisation is not technically feasible, data is destroyed using secure deletion methods compliant with recognised data sanitisation standards.

9. Your Privacy Rights

As an 88ku member and a data subject, you have the following rights with respect to your personal data. To exercise any of these rights, please contact our Data Protection team at [email protected] with the subject line "Privacy Rights Request". We will respond to verified requests within 30 calendar days.

9.1 Right to Access

You have the right to request a copy of the personal data we hold about you, including information about the purposes for which it is processed, the categories of data involved, and the third parties with whom it has been shared.

9.2 Right to Rectification

If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it. For identity-critical data (such as your legal name or date of birth), corrections will require supporting documentation.

9.3 Right to Erasure ("Right to Be Forgotten")

In certain circumstances, you have the right to request that we permanently delete your personal data. This right applies where:

• The data is no longer necessary for the purpose for which it was collected.
• You withdraw your consent and there is no other legal basis for processing.
• The data has been unlawfully processed.

Please note that this right is subject to limitations — we may be required to retain certain data to comply with legal obligations (for example, AML record-keeping requirements), and in such cases we will inform you of the specific retention period that applies.

9.4 Right to Restrict Processing

You may request that we restrict the processing of your data in certain circumstances, such as when you contest the accuracy of the data or object to our processing on the grounds of legitimate interests. During a restriction period, we will store your data but not actively process it.

9.5 Right to Data Portability

Where processing is based on your consent or on a contract, and is carried out by automated means, you have the right to receive a copy of your personal data in a structured, commonly used, machine-readable format (such as JSON or CSV). You may also request that we transmit this data directly to another service provider where technically feasible.

9.6 Right to Object

You have the right to object to processing based on our legitimate interests, and to the use of your data for direct marketing purposes. If you object to direct marketing, we will cease all such communications immediately and without requiring justification.

9.7 Right to Withdraw Consent

Where we rely on your consent as the legal basis for processing, you may withdraw that consent at any time by contacting us or updating your account preferences. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

10. Minors and Age Policy

The 88ku platform is intended exclusively for adults who are 21 years of age or older. We do not knowingly collect, process, or store 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 any bets placed from that account.
• Refund any deposited funds to the original payment source (subject to verification).
• Permanently delete all personal data associated with that account.

If you believe that a minor has accessed the Platform or that we may hold personal data belonging to someone under 21, please contact us immediately at [email protected]. We treat such reports with the highest urgency.

11. Changes to This Privacy Policy

88ku reserves the right to update or amend this Privacy Policy at any time. When we make material changes — changes that substantially affect your rights or the way we process your personal data — we will:

• Update the "Effective Date" at the top of this page.
• Send a notification to the email address registered to your account at least 14 days before the changes take effect.
• Display a prominent notice on the Site during the notification period.

Your continued use of the Services after the effective date of any updated Policy constitutes your acceptance of the revised terms. If you do not agree with the changes, you must stop using the Services and may request account closure by contacting customer support.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact our Data Protection team using the following details:

• Email: [email protected] (Subject: "Privacy Policy Enquiry" or "Privacy Rights Request")
• Live Chat: Available 24/7 via the platform after logging into your account.
• Response Time: We aim to acknowledge all privacy-related enquiries within 5 business days (WIB timezone) and to resolve them fully within 30 calendar days.

For matters specifically related to responsible gaming, account self-exclusion, or deposit limits, please visit our Responsible Gaming page or mark your support request as "Responsible Gaming – Urgent" to ensure expedited handling.