Privacy Policy — bts89 Data Commitment

The following terms carry the meanings set out below wherever they appear in this Privacy Policy.

This Privacy Policy applies to all Personal Data processed by bts89 in connection with the operation of the platform at https://bts89.cam. It covers data collected through the website, mobile-optimized interfaces, customer support channels, and any promotional communications we send to registered Players.

bts89 acts as the data controller for all Personal Data collected directly from Players. Where bts89 engages third-party processors — such as payment gateway providers, identity verification services, and certified game studios — those processors act under data processing agreements that obligate them to handle your data strictly in accordance with bts89's instructions and this Privacy Policy.

This policy is directed primarily at Players who are residents of Indonesia and who access bts89 from within the Indonesian archipelago, including but not limited to Jakarta, Surabaya, Medan, Bandung, Bali, Yogyakarta, Semarang, and Makassar. Players accessing the platform from other jurisdictions should be aware that their local data protection laws may confer additional or different rights — bts89 will make reasonable efforts to honor such rights where they are brought to our attention.

bts89 collects only the Personal Data that is necessary for the purposes described in Section 5 of this policy. The categories of data we may collect are set out in the table below.

bts89 does not intentionally collect sensitive personal data categories such as racial or ethnic origin, religious beliefs, political opinions, health data, or biometric data beyond what is strictly required for identity verification purposes.

bts89 collects Personal Data through the following channels:

• Direct Submission: Data you provide when registering an account, completing the KYC process, making a deposit or withdrawal request, contacting customer support, or participating in a promotion.
• Automated Technical Collection: Data gathered automatically as you interact with the platform — including IP address, device information, cookies, session logs, and behavioral analytics.
• Payment Processors: Confirmation data returned by Indonesian bank transfer gateways, e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja), and international card networks (Visa, Mastercard) following a deposit or withdrawal transaction.
• Identity Verification Partners: Results and data records from third-party KYC and fraud-prevention service providers engaged by bts89 to verify the accuracy of identity documents and detect fraudulent registrations.
• Publicly Available Sources: In limited circumstances, bts89 may cross-reference publicly available data — such as sanctions lists or fraud databases — to meet its compliance obligations.

bts89 processes your Personal Data only where a legitimate purpose and a recognized legal basis exists. The primary purposes for which we process your data are set out below.

• Account Registration and Management: To create, maintain, and secure your bts89 account, including verifying your identity and age (21+) in accordance with our eligibility requirements.
• Processing Transactions: To execute deposits and withdrawals in IDR via your chosen Indonesian bank or e-wallet, and to maintain an accurate record of your transaction history.
• KYC and Fraud Prevention: To verify that you meet the eligibility criteria in our Terms & Conditions, to detect and prevent fraud, money laundering, and other illegal activities, and to comply with applicable international anti-money-laundering standards.
• Responsible Gaming Monitoring: To monitor account activity for behavioral indicators of problem gambling, apply deposit limits and time-out tools as requested, and proactively reach out to Players who display signs of distress.
• Platform Operation and Security: To maintain the technical functionality of the bts89 platform, diagnose and resolve bugs, prevent unauthorized access, and protect the integrity of our systems.
• Customer Support: To respond to your inquiries, resolve disputes, and improve the quality of our support interactions.
• Marketing Communications: Where you have provided consent, to send you promotional offers, bonus notifications, and relevant platform updates. You may withdraw consent at any time by contacting support or using the unsubscribe mechanism in any marketing email.
• Analytics and Platform Improvement: To analyze aggregate usage data and understand how Players interact with the platform, enabling bts89 to improve features, user experience, and game selection.
• Legal and Regulatory Compliance: To comply with applicable legal obligations, respond to lawful requests from authorities, and enforce our Terms & Conditions.

bts89 does not sell your Personal Data. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in Section 5.

• Payment Service Providers: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata), e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja), and international card networks (Visa, Mastercard) receive the financial data necessary to process your transactions.
• Identity Verification Providers: Third-party KYC services receive identity document data strictly for the purpose of verifying your identity and age in support of our 21+ policy and anti-fraud obligations.
• Game Content Providers: Certified studios including Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Pocket Games Soft receive session and wagering data necessary to operate their games within the bts89 environment.
• Technology Infrastructure Providers: Cloud hosting, content delivery, and cybersecurity partners who process data on bts89's behalf under strict data processing agreements.
• Legal and Regulatory Authorities: Where required by applicable law, court order, or at the direction of a competent regulatory authority, bts89 may disclose Personal Data without prior notice to you.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of bts89's business, your Personal Data may be transferred to the acquiring entity, which will be bound by this Privacy Policy or a successor policy of equivalent standard.

bts89 retains your Personal Data only for as long as it is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and compliance obligations. The general retention periods applied by bts89 are as follows.

• Active Account Data: Retained for the full duration of your account relationship with bts89, plus a minimum of 5 years following account closure to meet anti-money-laundering record-keeping standards.
• KYC and Identity Documents: Retained for a minimum of 5 years from the date of account closure or the completion of the last transaction, whichever is later.
• Transaction Records: Retained for a minimum of 5 years from the date of each transaction in accordance with international financial compliance standards.
• Customer Support Records: Retained for 3 years following the resolution of a support interaction, or longer if the interaction relates to a dispute that remains unresolved.
• Marketing Consent Records: Retained for the period of your consent, plus 2 years following withdrawal of consent, to demonstrate compliance with consent-based processing obligations.
• Technical and Log Data: Typically retained for 12 months, except where specific logs are required for an active security investigation or legal proceeding.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymized so that it can no longer be associated with you as an individual.

bts89 implements a multi-layered security framework to protect your Personal Data against unauthorized access, accidental loss, alteration, or disclosure. Our security measures include, but are not limited to:

• 256-Bit SSL/TLS Encryption: All data in transit between your device and bts89 servers is encrypted using industry-standard TLS protocols.
• Encryption at Rest: Sensitive data stored on bts89 servers — including financial records and KYC documents — is encrypted at rest using AES-256 or equivalent standards.
• Access Controls: Access to systems containing Personal Data is restricted to authorized bts89 personnel on a strict need-to-know basis, enforced through role-based access controls and multi-factor authentication.
• Regular Security Audits: bts89 conducts regular internal and third-party security assessments, penetration testing, and vulnerability scans of platform infrastructure.
• Incident Response: bts89 maintains a documented data breach response procedure. In the event of a breach that poses a risk to your rights and freedoms, we will notify affected Players without undue delay and take all reasonable steps to contain and mitigate the incident.
• Employee Training: All bts89 staff with access to Personal Data receive regular data protection and security awareness training.

bts89 uses cookies and similar tracking technologies to ensure the correct functioning of the platform, remember your preferences, and analyze how Players use our services. The categories of cookies we use are described below.

bts89 does not use advertising or retargeting cookies. We do not place third-party advertising network cookies on the bts89 platform.

You may control cookie settings through your browser preferences. Please be aware that disabling strictly necessary cookies may impair your ability to log in or use core platform features. For analytics and functional cookies, you may opt out by adjusting your browser settings or by contacting bts89 support.

As a Player whose Personal Data is processed by bts89, you hold the following rights with respect to your information. To exercise any of these rights, please contact our support team at [email protected] with a clear description of your request. We will respond within 30 days of receiving a valid and complete request.

• Right of Access: You may request a copy of the Personal Data that bts89 holds about you, together with information about the purposes for which it is processed.
• 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 complete it without undue delay.
• 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, where you withdraw consent (and no other legal basis applies), or where you object to processing and bts89 has no overriding legitimate interest. Please note that certain data must be retained to meet legal and compliance obligations even following a deletion request.
• Right to Restriction of Processing: You may request that bts89 restrict processing of your Personal Data in certain circumstances — for example, while the accuracy of data is being contested.
• Right to Data Portability: Where processing is based on your consent or on the performance of a contract, you may request that we provide your Personal Data in a structured, commonly used, machine-readable format.
• Right to Object: You may object at any time to processing of your Personal Data where that processing is based on bts89's legitimate interests, including direct marketing communications.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

The bts89 platform integrates with a range of third-party service providers to deliver a complete betting and casino experience. Each provider is selected on the basis of its technical quality, security standards, and willingness to enter into a data processing agreement with bts89.

Key categories of third-party services that may process your Personal Data include:

• Game Studios: Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Pocket Games Soft operate their respective games within the bts89 environment. These providers receive only the session and wagering data technically necessary to run their games and determine outcomes.
• Payment Processors: Indonesian banking partners and e-wallet operators receive financial transaction data strictly for the purpose of processing deposits and withdrawals in IDR.
• KYC & Anti-Fraud Providers: Specialized identity verification and fraud-detection services process KYC documents and behavioral signals to support bts89's compliance obligations.
• Analytics Providers: Platform analytics tools receive anonymized or pseudonymized behavioral data to help bts89 understand aggregate usage patterns.

bts89 is not responsible for the privacy practices of third-party providers in respect of data that those providers collect independently of their relationship with bts89. We recommend reviewing the privacy policies of any third-party services you interact with directly.

bts89 operates a strict Adults Only policy. The platform is intended exclusively for individuals who are 21 years of age or older. bts89 does not knowingly collect Personal Data from anyone under the age of 21.

If bts89 discovers or has reasonable grounds to believe that Personal Data has been collected from a person under 21 years of age, the following steps will be taken without delay:

• The account will be immediately suspended pending investigation.
• All transactions associated with the account will be voided and deposits returned to the originating payment source.
• All Personal Data associated with the underage account will be securely deleted, except where retention is required by applicable law or to report the incident to relevant authorities.

bts89 operates internationally and may transfer your Personal Data to servers or service providers located outside of Indonesia. Where such transfers occur, bts89 ensures that adequate safeguards are in place to protect your data to a standard equivalent to that described in this Privacy Policy.

Safeguards applied for international data transfers include:

• Contractual data processing agreements incorporating internationally recognized data transfer clauses with all third-party processors located outside Indonesia.
• Transfer only to jurisdictions that maintain an adequate level of data protection as assessed by bts89's compliance team.
• Application of the same encryption and access control standards to data in transit across borders as to data processed within Indonesia.

bts89 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform functionality. The date of the most recent revision is displayed at the top of this page.

Where changes are material — for example, where we introduce a new purpose for processing your Personal Data or a new category of third-party recipient — bts89 will provide advance notice by publishing the updated policy on this page and, where appropriate, by sending a notification to the email address registered to your account.

Your continued use of the bts89 platform following the effective date of any revised Privacy Policy constitutes your acknowledgment of, and agreement to, the updated terms. If you do not accept the revised policy, you should cease using the platform and request account closure as described in Section 10 (Right to Erasure) above.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way bts89 processes your Personal Data, please contact our support team using the details below. All privacy-related inquiries are handled by staff trained in data protection obligations.

For responsible gaming support, self-exclusion requests, or any concern that gambling activity may be causing you distress, please visit our dedicated Responsible Gaming page for tools and guidance.