ink78 Privacy Policy

1. Introduction and Scope

ink78 ("we," "us," "our," or the "Operator") operates the online betting and casino platform accessible at https://ink78.cam (the "Platform"). This Privacy Policy ("Policy") describes how ink78 collects, uses, stores, shares, and protects personal information provided by users ("you," "Player," or "User") when you access the Platform, register an Account, place wagers, or interact with our customer support team.

This Policy applies to all users of the ink78 Platform, including visitors who have not registered, registered Players, and individuals who contact ink78 via email, live chat, or WhatsApp. By accessing the Platform or registering an Account, you acknowledge that you have read, understood, and consent to the data practices described in this Policy.

ink78 primarily serves Indonesian players and English-preference users across Southeast Asia. This Policy is written in accordance with internationally recognized data protection principles, including those set out in the European Union's General Data Protection Regulation (GDPR) and applicable data protection frameworks, as reference standards for best practice — even where local Indonesian law does not mandate an equivalent standard.

2. Definitions

• "Personal Data" means any information that identifies or can be used to identify you as an individual, including your name, email address, date of birth, National ID (KTP), phone number, IP address, and payment details.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, transmission, or deletion.
• "Data Controller" refers to ink78 as the entity that determines the purposes and means of processing your Personal Data.
• "Third Party" means any individual or entity other than you and ink78, including payment processors, game studios, identity verification providers, and analytics services.
• "Cookies" are small data files placed on your device when you visit the Platform to improve functionality, remember preferences, and support analytics.
• "KYC" (Know Your Customer) refers to the identity verification process required to comply with anti-money-laundering regulations and to confirm Player eligibility.

3. Data We Collect

3.1 Information You Provide Directly

When you register an Account or use our services, we collect information you submit directly, including:

• Registration data: Full legal name, date of birth, email address, phone number, and residential address.
• Identity verification (KYC) documents: Government-issued ID (KTP Nasional or equivalent), proof of address (utility bill, bank statement), and a selfie photograph for identity confirmation.
• Payment information: Bank account details (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja), and transaction history. We do not store complete card numbers; payment processing is handled by certified third-party payment processors.
• Support communications: Messages, emails, live chat transcripts, and WhatsApp conversations with our customer support team.

3.2 Information We Collect Automatically

When you access the Platform, certain information is collected automatically, including:

• IP address, device type, operating system, and browser type.
• Pages viewed, features used, time spent on page, and navigation paths within the Platform.
• Login timestamps and session duration data.
• Wager history, game selections, bet amounts, and win/loss records.
• Cookies and similar tracking technology data (see Section 7).

3.3 Information from Third Parties

We may receive information about you from third parties in limited circumstances, including:

• Identity verification providers who confirm the authenticity of documents submitted during KYC.
• Payment processors who confirm transaction status and flag suspicious payment activity.
• Fraud detection and anti-money-laundering screening services.

4. How We Use Your Data

ink78 uses the Personal Data we collect for the following purposes:

• Account management: Creating, maintaining, and securing your Account; verifying your identity during registration and ongoing KYC processes.
• Service delivery: Processing deposits and withdrawals, settling wagers, crediting bonuses, and providing access to games and betting markets.
• Regulatory compliance: Meeting anti-money-laundering (AML) obligations, age verification requirements (21+ minimum), and responsible gaming mandates imposed by our licensing jurisdiction.
• Customer support: Responding to inquiries, resolving disputes, processing Account closure or self-exclusion requests, and communicating important Account updates.
• Security and fraud prevention: Detecting, investigating, and preventing unauthorized Account access, fraudulent transactions, bonus abuse, and Terms violations.
• Platform improvement: Analyzing aggregated usage data to improve Platform performance, fix bugs, and develop new features.
• Marketing communications: Sending promotional offers, bonus announcements, and platform news to Players who have opted in to marketing communications. You may opt out at any time by contacting support or clicking "Unsubscribe" in any email communication.
• Responsible gaming: Monitoring play patterns to identify potential problem gambling indicators and providing appropriate support tools or interventions where warranted.

5. Legal Basis for Processing

Where applicable under international data protection frameworks, ink78 processes your Personal Data on the following legal bases:

• Contractual necessity: Processing required to fulfill our obligations under the User Agreement (Terms & Conditions), including Account management, payment processing, and service delivery.
• Legal obligation: Processing required to comply with AML regulations, KYC obligations, age verification requirements, and applicable laws of our licensing jurisdiction.
• Legitimate interests: Processing for fraud detection, security monitoring, and Platform improvement, where these interests are not overridden by your rights and freedoms.
• Consent: Processing for marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time.

6. Data Sharing and Disclosure

ink78 does not sell, rent, or trade your Personal Data to third parties for their own commercial purposes. We may share your data in the following limited circumstances:

• Payment processors: We share payment details with certified payment processors (handling BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, and other methods) strictly for the purpose of processing deposits and withdrawals.
• Identity verification providers: KYC documents are shared with accredited identity verification partners solely to confirm authenticity and Player eligibility.
• Game studios and content providers: Minimum necessary data (e.g., session tokens) may be shared with studios (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming) to facilitate game play. Studios do not receive personally identifying information beyond what is technically necessary.
• Legal and regulatory authorities: We will disclose Personal Data to law enforcement, regulators, or courts where required by law, court order, or regulatory mandate in our licensing jurisdiction.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of ink78's business, Personal Data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third-party service providers engaged by ink78 are contractually obligated to process Personal Data only for specified purposes, in compliance with applicable data protection standards, and with appropriate technical and organizational security measures in place.

7. Cookies and Tracking Technologies

The ink78 Platform uses cookies and similar tracking technologies to improve functionality, remember your preferences, maintain session state, and collect analytics data. We use the following categories of cookies:

• Essential cookies: Required for the Platform to function correctly. These include session authentication cookies and security tokens. They cannot be disabled without disrupting Platform functionality.
• Functional cookies: Remember your language and display preferences to personalize your experience.
• Analytics cookies: Collect anonymized or aggregated data about how users navigate the Platform (pages visited, time on site, click patterns). This data helps us identify and fix usability issues.
• Marketing cookies: Used to deliver relevant promotional content based on your betting preferences and Platform activity. These are only set if you have consented to marketing communications.

You can manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from using the Platform, but may limit certain personalization features.

8. Data Retention

ink78 retains Personal Data for as long as necessary to fulfill the purposes outlined in this Policy and to comply with legal and regulatory retention obligations. Specific retention periods include:

• Account data: Retained for the duration of your Account plus a minimum of five (5) years following Account closure, as required by AML and financial record-keeping regulations.
• KYC documents: Retained for five (5) years after the end of the customer relationship, as required by anti-money-laundering frameworks.
• Transaction records: Retained for a minimum of five (5) years for audit, compliance, and dispute resolution purposes.
• Support communications: Retained for two (2) years from the date of the communication, unless relevant to an ongoing dispute or regulatory matter.
• Marketing data: Retained until you withdraw consent or opt out of marketing communications.

After the applicable retention period expires, Personal Data is securely deleted or anonymized so that it can no longer identify you as an individual.

9. Data Security

ink78 implements industry-standard technical and organizational security measures to protect your Personal Data from unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL (TLS 1.3) encryption for all data transmitted between your device and our servers.
• AES-256 encryption for Personal Data stored in our databases, including KYC documents and payment details.
• Two-factor authentication (2FA) available for all user Accounts.
• Access controls limiting internal access to Personal Data to employees with a documented need-to-know.
• Regular third-party penetration testing and security audits.
• PCI DSS-compliant payment infrastructure for all card and e-wallet transaction processing.

While we take all reasonable steps to protect your data, no system is entirely immune from security threats. In the event of a data breach that is likely to result in material risk to your rights, we will notify affected users and relevant authorities as required by applicable regulations.

10. Your Rights as a Data Subject

Subject to applicable law and regulatory limitations, you have the following rights with respect to your Personal Data held by ink78:

• Right of Access: You may request a copy of the Personal Data we hold about you, along with information about how it is used.
• Right to Rectification: If any Personal Data we hold is inaccurate or incomplete, you may request correction.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your Personal Data where we no longer have a legal basis to retain it. Note that certain data must be retained for AML and regulatory compliance and cannot be deleted on request alone.
• Right to Restrict Processing: You may request that we limit how we use your Personal Data in certain circumstances (e.g., while a dispute is being investigated).
• Right to Data Portability: You may request a copy of your Personal Data in a structured, machine-readable format for transfer to another service provider.
• Right to Object: You may object to processing of your Personal Data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to our ability to demonstrate overriding grounds.
• Right to Withdraw Consent: Where processing is based on consent (e.g., marketing emails), you may withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact our support team via live chat or email (plain text: [email protected]). We aim to respond to all data subject requests within 30 days. We may require identity verification before processing requests to protect against unauthorized data access.

11. Children's Privacy

The ink78 Platform is strictly intended for adults aged 21 years and over. We do not knowingly collect Personal Data from individuals under the age of 21. If you believe a person under 21 has submitted Personal Data to ink78, please contact us immediately so that we can delete the information and close the associated Account. Parents and guardians who are concerned about underage gambling activity can also visit our Responsible Gaming page for guidance on parental controls and blocking tools.

12. Cross-Border Data Transfers

ink78 operates internationally and may transfer your Personal Data to servers, service providers, and subsidiaries located outside Indonesia. Where such transfers occur, we implement appropriate safeguards to ensure an adequate level of data protection, including contractual clauses based on recognized data protection standards. By using the Platform, you consent to the transfer of your Personal Data across borders as described in this Policy.

13. Changes to This Policy

ink78 reserves the right to update this Privacy Policy at any time. Material changes will be communicated via email notification to registered Players and/or a prominent notice on the Platform at least seven (7) days before the changes take effect. The "Last Updated" date at the top of this Policy reflects the most recent revision. Continued use of the Platform after the effective date of any revision constitutes acceptance of the updated Policy.

We encourage you to review this Policy periodically to stay informed about how we protect your Personal Data. Archived versions of previous Privacy Policies are available on request.

14. Contact and Data Requests

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your Personal Data, please contact ink78 through the following channels:

• Live Chat: Available 24/7 through the in-app chat interface on the Platform.
• WhatsApp: Contact details available within the Platform after Account login.
• Email (plain text — not a clickable link): [email protected]

Indonesian-speaking support agents are on duty during WIB business hours (UTC+7) and can assist with data requests in Bahasa Indonesia if preferred. All formal data subject access requests should be made in writing via email for proper documentation and tracking.