Privacy Policy

1. Definitions

The following terms have specific meanings throughout this Privacy Policy:

• "Personal Data" — any information that identifies or could reasonably identify a living individual, including but not limited to name, national identity number (KTP number), date of birth, residential address, email address, mobile phone number, IP address, device identifiers, and financial account details.
• "Processing" — any operation performed on Personal Data, including collection, recording, organisation, storage, adaptation, retrieval, use, disclosure, or erasure.
• "Platform" — the emas36 website at https://emas36.cam, any associated mobile applications, APIs, or digital interfaces operated by the Company.
• "Account" — the registered user account you create to access emas36 Services.
• "Third-Party Service Provider" — any external company engaged by emas36 to assist in operating the Platform or delivering Services, such as payment processors, KYC verification providers, analytics platforms, and customer support tools.
• "Cookies" — small text files stored on your device by your browser when you visit the Platform, used to improve functionality and user experience.

2. Who We Are and How to Contact Us

emas36 is an international online gaming platform serving players primarily based in Indonesia. We operate as the data controller responsible for Personal Data processed through the Platform. Our registered data-protection contact is reachable at:

• Email: [email protected]
• Response time: We aim to respond to all privacy-related enquiries within five (5) business days.

All correspondence regarding your data rights, access requests, rectification requests, or complaints should be directed to the email address above.

3. Personal Data We Collect

3.1 Data You Provide Directly

When you register an Account, interact with our Services, or contact our support team, we collect the following categories of Personal Data:

• Registration information: Full legal name, date of birth, gender, email address, mobile phone number, and chosen password (stored as a one-way hash).
• Identity verification (KYC): Scanned copy or photograph of your government-issued national identity card (KTP — Kartu Tanda Penduduk for Indonesian residents), proof of residential address (utility bill or bank statement), and where required, a selfie photograph for facial verification.
• Financial information: Indonesian bank account details (bank name, account number, and account holder name) and e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, or LinkAja account IDs) used for deposits and withdrawals. We do not store full payment credentials; payment processing is handled by certified third-party payment gateways.
• Communications: Content of messages sent through our live chat, WhatsApp support channel, or email, including support tickets and dispute records.

3.2 Data Collected Automatically

When you access the Platform, we automatically collect the following technical and behavioural data:

• Device and connection data: IP address, device type and model, operating system and version, browser type and version, screen resolution, and internet service provider.
• Usage data: Pages visited, features accessed, games played (including bet amounts, game results, session duration, and wagering history), time and date of access, and navigation paths through the Platform.
• Cookie and tracking data: Session cookies, preference cookies, analytics cookies, and, where consented, advertising cookies. See Section 9 for full cookie details.
• Location data: Approximate geographic location derived from your IP address (country and city level). We do not collect precise GPS coordinates unless you explicitly grant location access on a mobile device.

3.3 Data from Third Parties

We may receive supplementary Personal Data from trusted third-party sources to assist with identity verification, fraud prevention, and compliance obligations. These sources include KYC verification bureaus, credit-risk assessment providers, and anti-fraud network databases. Such data is processed strictly for the purposes described in Section 4 below.

4. How We Use Your Personal Data

emas36 processes your Personal Data for the following specific, lawful purposes:

4.1 Account Management and Service Delivery

We use your registration information and financial data to create and manage your Account, process deposits and withdrawals via Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, and others) and e-wallets, and provide you access to our full range of gaming services including sports betting on BRI Liga 1 and international leagues, casino games, togel (traditional lottery) markets, and slot games. This processing is necessary to perform our contractual obligations to you.

4.2 Identity Verification and KYC Compliance

Indonesian anti-money laundering regulations and our international licensing obligations require us to verify the identity of all players, particularly before processing withdrawals. We use your KTP document, proof of address, and other identity data solely for this verification purpose. Verified documents are retained for the minimum period required by applicable law.

4.3 Security, Fraud Prevention, and Legal Compliance

We analyse Account activity, betting patterns, IP addresses, and device fingerprints to detect and prevent fraudulent activity, money laundering, bonus abuse, and other prohibited behaviours. This processing is based on our legitimate interest in maintaining the integrity of our Platform and protecting our users and the Company from financial harm.

4.4 Customer Support

When you contact our support team, we use the information you provide — together with your Account history — to resolve your issue efficiently. Support interactions are recorded and retained for quality assurance and dispute resolution purposes.

4.5 Responsible Gaming Compliance

We monitor gameplay data and Account activity to identify signs of problem gambling and to enforce responsible gaming tools such as deposit limits, self-exclusion periods, and reality checks. This processing is both a legal obligation and a core company value.

4.6 Marketing and Promotional Communications

With your explicit consent, we may send you promotional emails, SMS messages, or in-app notifications about bonuses, new game releases, seasonal promotions (such as offers during Idul Fitri, Indonesian Independence Day on 17 August, and Ramadhan), and other emas36 news. You may withdraw your marketing consent at any time by contacting support or adjusting your Account notification preferences. Withdrawal of marketing consent does not affect service-related communications, which are necessary for Account management.

4.7 Platform Improvement and Analytics

Aggregated and anonymised usage data helps us improve Platform performance, user experience, game selection, and feature development. Individual user data contributing to these analytics is not disclosed in identifiable form.

5. Legal Bases for Processing

We process your Personal Data on the following legal grounds:

• Contractual necessity: Processing required to create your Account, provide Services, and process financial transactions.
• Legal obligation: Processing required to comply with KYC, AML, and data-retention laws applicable to our operations.
• Legitimate interests: Processing for fraud prevention, security, and platform analytics, where these interests are not overridden by your rights.
• Consent: Processing for optional marketing communications, where you have freely given specific consent.

6. How We Share Your Personal Data

6.1 Third-Party Service Providers

emas36 engages trusted Third-Party Service Providers to support Platform operations. These providers access your Personal Data only to the extent strictly necessary to perform their contracted functions, are bound by confidentiality obligations, and are prohibited from using your data for any other purpose. Categories of providers include:

• Payment processing partners handling bank transfers and e-wallet transactions
• KYC and identity verification bureaus performing document authentication
• Cloud infrastructure and hosting providers storing encrypted platform data
• Customer support technology platforms managing live chat and ticketing systems
• Web analytics providers supplying anonymised traffic and behaviour data
• Anti-fraud and cybersecurity services monitoring for suspicious activity

6.2 Legal and Regulatory Disclosure

We may disclose Personal Data to law enforcement authorities, regulatory bodies, or courts when required by law, a valid court order, or a legally enforceable regulatory request. We will notify you of such disclosures to the extent permitted by law.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of our business assets, your Personal Data may be transferred to the acquiring entity. We will provide notice of any such transfer and the new privacy terms that will apply.

6.4 No Sale of Personal Data

emas36 does not sell, rent, or trade your Personal Data to third parties for their own marketing or commercial purposes. This commitment is absolute and not subject to any commercial arrangement.

7. Data Retention

We retain Personal Data for as long as necessary to fulfil the purposes for which it was collected, subject to the following principles:

• Active Account data: Retained for the duration of your Account and for a minimum of five (5) years after Account closure, as required by our AML and KYC compliance obligations.
• Transaction records: Financial transaction records are retained for seven (7) years following the transaction date in accordance with financial record-keeping requirements.
• Support communications: Retained for two (2) years from the date of last interaction, unless longer retention is required for dispute resolution purposes.
• Marketing consent records: Retained until you withdraw consent plus one (1) additional year for compliance audit purposes.
• Technical logs: Server logs and access records are retained for ninety (90) days and then permanently deleted.

Upon expiry of the applicable retention period, data is securely deleted or anonymised using industry-standard methods.

8. Your Data Rights

Subject to applicable law, you have the following rights regarding your Personal Data held by emas36:

• Right of access: You may request a copy of the Personal Data we hold about you, along with information about how it is processed.
• Right to rectification: You may request correction of inaccurate or incomplete Personal Data.
• Right to erasure: You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to restrict processing: You may request that we limit processing of your data in certain circumstances, such as while a dispute is under investigation.
• Right to data portability: You may request a machine-readable copy of Personal Data you provided to us, where technically feasible.
• Right to withdraw consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to object: You may object to processing based on our legitimate interests, and we will cease processing unless we demonstrate compelling legitimate grounds that override your interests.

To exercise any of these rights, please contact us at [email protected] with the subject line "Data Rights Request" and your full Account details. We will respond within thirty (30) days and may request identity verification before processing your request.

9. Cookies and Tracking Technologies

9.1 Types of Cookies Used

The emas36 Platform uses the following categories of cookies:

• Strictly necessary cookies: Essential for Platform functionality, including session authentication, security tokens, and payment processing handshakes. These cannot be disabled without impairing your ability to use the Platform.
• Performance and analytics cookies: Collect anonymised data on how users navigate the Platform, which pages are visited most, and where technical errors occur. Used to improve Platform performance and user experience.
• Functionality cookies: Remember your preferences such as language settings, display preferences, and recently played games to personalise your experience.
• Targeting and advertising cookies: Used only with your explicit consent to deliver relevant promotional content. These cookies track browsing act ivity across sessions to help us understand the effectiveness of our promotional campaigns.

9.2 Managing Your Cookie Preferences

You may control cookie settings through your browser preferences at any time. Most modern browsers allow you to block or delete cookies, though disabling strictly necessary cookies will affect Platform functionality. Blocking performance or advertising cookies will not prevent you from using our Services. Please consult your browser's help documentation for instructions on managing cookie settings.

10. Data Security

emas36 implements a comprehensive suite of technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, destruction, or disclosure:

• Encryption in transit: All data exchanged between your device and our servers is protected by 256-bit SSL/TLS encryption, the same standard used by major international banks.
• Encryption at rest: Sensitive Personal Data stored in our databases is encrypted using AES-256 encryption with access keys managed under strict key-management protocols.
• Access controls: Access to systems holding Personal Data is restricted to authorised personnel on a strict need-to-know basis. All internal access is logged and audited.
• Penetration testing: Our Platform undergoes regular independent security audits and penetration tests to identify and remediate vulnerabilities proactively.
• Multi-factor authentication: Internal administrative systems require multi-factor authentication for all staff access.
• Incident response: We maintain a documented data breach response plan. In the event of a breach affecting your Personal Data, we will notify you and relevant authorities within the timeframes required by applicable law.

While we apply industry-leading security practices, no digital system can be guaranteed entirely free from risk. You are responsible for keeping your Account password confidential and for notifying us immediately if you suspect unauthorised access to your Account.

11. International Data Transfers

emas36 operates internationally, and your Personal Data may be transferred to and processed in countries outside Indonesia where our servers, Third-Party Service Providers, or operational teams are located. Where such transfers occur, we ensure that appropriate safeguards are in place — including contractual data-protection clauses and equivalent privacy standards — to protect your data to the same level as it would receive under this Privacy Policy. By using our Platform, you acknowledge and consent to these international transfers as described herein.

12. Children and Minors

emas36 strictly prohibits use of its Platform by individuals under twenty-one (21) years of age. We do not knowingly collect Personal Data from persons under this age threshold. If we discover that an Account has been registered by or on behalf of a minor, we will immediately close that Account, forfeit any associated balance, and permanently delete all collected data. If you have reason to believe that a minor has registered on our Platform, please contact us immediately at [email protected].

13. Links to Third-Party Platforms

Our Platform may reference third-party services such as payment processors or game studios. These third parties operate their own independent privacy policies, for which emas36 bears no responsibility. We encourage you to review the privacy practices of any third-party service before sharing your personal information with them.

14. Changes to This Privacy Policy

We reserve the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or business operations. When we make material changes, we will post the revised policy on this page with an updated "Last Updated" date and send a notification to your registered email address. Your continued use of the Platform following such notification constitutes acceptance of the revised Privacy Policy. We recommend revisiting this page periodically.

15. Governing Law and Jurisdiction

This Privacy Policy is governed by and construed in accordance with applicable international data protection standards and the laws of our licensing jurisdiction. Any disputes arising from or relating to this Privacy Policy that cannot be resolved through direct correspondence shall be subject to the dispute resolution procedures outlined in our Terms & Conditions.

16. Contact and Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or the way we handle your Personal Data, please contact our data protection team:

• Email: [email protected]
• Subject line: "Privacy Enquiry" or "Data Rights Request"
• Response time: Within five (5) business days for general enquiries; within thirty (30) days for formal data rights requests

We take all privacy complaints seriously and will work with you in good faith to reach a fair resolution.