Privacy Policy

Welcome to the soju89 Privacy Policy. This document governs the collection, use, storage, and protection of personal information provided by users of the soju89 online gaming platform, accessible at soju89.cam. By creating an account, depositing funds, or otherwise using our services, you acknowledge that you have read, understood, and agreed to the practices described in this Privacy Policy.

soju89 respects your right to privacy and is committed to safeguarding the personal data you entrust to us. This policy applies to all users who access soju89 from any jurisdiction, with particular emphasis on players accessing the platform from Indonesia.

For the purposes of applicable data protection laws, the data controller responsible for your personal information is the corporate entity operating the soju89 platform under its international gaming licence. The data controller determines the purposes and means of processing personal data collected through the platform.

All enquiries regarding the processing of your personal data should be directed to our Data Protection Officer via email at [email protected], clearly marking your correspondence as "Data Protection Enquiry" in the subject line.

soju89 collects several categories of personal information in order to provide our gaming services, comply with regulatory obligations, and ensure platform security. The data we collect includes:

3.1 Account Registration Data

• Personal Identifiers: Full legal name as it appears on government-issued identification documents.
• Date of Birth: Used to verify that you meet the minimum age requirement of 21 years.
• Email Address: Your primary contact method for account communications, promotions, and security alerts.
• Phone Number: Mobile number for account verification, two-factor authentication (if enabled), and customer support.
• Username & Password: Self-selected credentials that grant access to your account.
• Residential Address: Street address, city, province, and postal code within Indonesia.

3.2 Identity Verification (KYC) Data

• Government-Issued ID: Scanned copy or photograph of your Indonesian national identity card (KTP), passport, or driving licence.
• Proof of Address: Recent utility bill, bank statement, or official correspondence dated within the last three months.
• Facial Verification: Photograph or selfie taken at the time of verification (liveness check) to match against the photo ID.
• Source of Funds Documentation: Where required by enhanced due-diligence procedures, evidence of the legitimate origin of deposited funds (e.g., payslips, bank statements, business ownership documents).

3.3 Financial & Transaction Data

• Payment Method Information: Bank account details (bank name, account number, account holder name), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay account names/numbers).
• Deposit & Withdrawal Records: Date, time, amount, currency (IDR), method, and status of every financial transaction on your account.
• Betting History: Complete log of all bets placed, including stake amounts, odds, selections, outcomes, and settlement times.
• Bonus & Promotional Activity: Record of bonuses claimed, wagering progress, and bonus fund conversions.

3.4 Technical & Device Data

• IP Address: Internet Protocol address of the device used to access soju89, used for geolocation verification and fraud prevention.
• Device Information: Device type (mobile, tablet, desktop), operating system (Android, iOS, Windows, macOS), browser type and version.
• Usage Data: Pages visited, features accessed, session duration, click paths, and in-platform navigation patterns.
• Cookies & Similar Technologies: See Section 11 (Cookies & Tracking) for full details.

3.5 Communications Data

• All communications between you and soju89, including live chat transcripts, email correspondence, WhatsApp messages, and support ticket content.
• Feedback, complaints, and survey responses submitted voluntarily by you.

Personal data is collected through the following channels:

• Direct Provision: Information you provide directly when creating an account, uploading KYC documents, making deposits, or contacting customer support.
• Automated Collection: Technical data collected automatically via cookies, web beacons, and server logs when you access or navigate the soju89 platform.
• Third-Party Sources: In limited cases, we may receive information from payment service providers (banks, e-wallet operators) confirming the completion of transactions, or from identity verification partners assisting with KYC checks.
• Public Sources: Where necessary for fraud prevention or AML compliance, we may cross-reference your information against publicly available databases or sanctions lists.

soju89 collects and processes personal data for the following purposes, all of which are necessary to provide our gaming services or to comply with legal obligations:

• Account Management: Creating, maintaining, and administering your player account.
• Service Delivery: Processing deposits and withdrawals, placing bets, crediting winnings, and delivering promotional bonuses.
• Identity Verification (KYC): Verifying your age (21+), confirming your identity, and ensuring you are not accessing the platform from a prohibited jurisdiction.
• Fraud Prevention & Security: Detecting and preventing fraudulent activity, collusion, money laundering, and unauthorised account access.
• Regulatory Compliance: Meeting anti-money laundering (AML) and counter-terrorist financing (CTF) obligations under the laws of our licensing jurisdiction.
• Customer Support: Responding to your enquiries, resolving disputes, and investigating complaints.
• Marketing & Communications: Sending promotional offers, newsletters, and platform updates (you may opt out of marketing communications at any time via your account settings or by contacting support).
• Platform Improvement: Analysing usage patterns to enhance user experience, optimise game offerings, and improve technical performance.
• Legal Obligations: Responding to valid legal requests from law enforcement, regulatory authorities, or courts.

Under international data protection standards, personal data may only be processed where there is a valid legal basis. soju89 relies on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform the contract between you and soju89 (the Terms & Conditions you agreed to when registering). This covers account management, payment processing, and service delivery.
• Legal Obligation: Processing is required to comply with applicable laws, including KYC/AML regulations, licensing conditions, and tax reporting obligations.
• Legitimate Interests: Processing is necessary for soju89's legitimate business interests, such as fraud prevention, platform security, internal analytics, and direct marketing (provided your interests and rights do not override these purposes).
• Consent: Where required by law, we obtain explicit consent for specific processing activities, such as sending promotional emails or using certain types of cookies. You may withdraw consent at any time.

soju89 does not sell, rent, or otherwise transfer your personal data to third parties for their own marketing purposes. However, we do share data with the following categories of third parties where necessary:

7.1 Payment Service Providers

Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, Bank Permata) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) receive the minimum personal data necessary to process deposits and withdrawals — typically your name and account identifier.

7.2 KYC & Identity Verification Partners

Third-party identity verification providers may process KYC documents (ID cards, passports, proof of address) on behalf of soju89 to verify your identity and age. These processors are contractually bound to use your data solely for verification purposes and to maintain strict confidentiality.

7.3 Game Providers & Platform Partners

Casino game studios (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, PG Soft, Spribe) and sportsbook data providers receive pseudonymised player identifiers and betting data necessary to deliver live game streams, calculate odds, and settle wagers. No identifiable personal information is shared without necessity.

7.4 Regulatory & Law Enforcement Authorities

soju89 may disclose personal data to licensing authorities, regulators, law enforcement agencies, or courts where required by law, court order, or regulatory request. This includes AML reporting obligations and responses to valid legal process.

7.5 Professional Advisors

Legal counsel, auditors, and compliance consultants may access personal data on a confidential basis to advise soju89 on regulatory matters or to conduct required audits.

As an international online gaming operator, soju89 may transfer personal data outside Indonesia to the jurisdiction in which our servers are located or where third-party service providers operate. All international transfers are conducted in accordance with applicable data protection laws and are subject to appropriate safeguards, including:

• Standard Contractual Clauses: Transfers to third-party processors are governed by data processing agreements incorporating standard contractual clauses approved by international regulatory authorities.
• Adequacy Decisions: Where applicable, we transfer data only to jurisdictions that have been deemed to provide an adequate level of data protection.
• Technical & Organisational Measures: All data in transit between jurisdictions is encrypted using SSL/TLS protocols, and data at rest is stored on secure, access-controlled servers.

By using soju89, you acknowledge and consent to the international transfer of your personal data as described in this policy.

soju89 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

At the end of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be associated with an identifiable individual.

soju89 employs industry-standard technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS protocols. Sensitive data stored in our databases (including passwords) is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorised personnel only, on a need-to-know basis. Multi-factor authentication is required for administrative access to systems holding personal data.
• Regular Security Audits: soju89 undergoes periodic third-party security assessments and penetration testing to identify and remediate vulnerabilities.
• Data Centre Security: Physical servers are housed in certified data centres with 24/7 security monitoring, biometric access controls, and environmental protections (fire suppression, climate control).
• Incident Response: A documented incident response plan is in place to detect, contain, and remediate security breaches. In the event of a data breach affecting your personal information, soju89 will notify you and relevant authorities in accordance with applicable breach notification laws.

soju89 uses cookies and similar tracking technologies to enhance your browsing experience, analyse platform usage, and deliver personalised content. A cookie is a small text file stored on your device by your web browser.

11.1 Types of Cookies Used

• Essential Cookies: Required for core platform functionality, including session management, login authentication, and security features. These cookies cannot be disabled without impairing platform usability.
• Performance Cookies: Collect anonymised data on how users interact with the platform (pages visited, session duration, error messages) to help us identify and fix technical issues.
• Functional Cookies: Remember your preferences (language settings, display options) to provide a more personalised experience on repeat visits.
• Analytical Cookies: Third-party analytics tools (e.g., Google Analytics) track aggregated usage patterns to help soju89 understand user behaviour and improve the platform.
• Marketing Cookies: Track your activity across websites to deliver targeted promotional offers. These cookies require your consent and can be disabled via your account settings or browser preferences.

11.2 Managing Cookies

You can control or delete cookies through your browser settings. Most browsers allow you to refuse cookies or to alert you when a cookie is being sent. However, disabling certain cookies (especially essential cookies) may impair your ability to use soju89's full range of features.

For more information on managing cookies, consult your browser's help documentation or visit www.allaboutcookies.org (external resource — soju89 is not responsible for third-party websites).

Under applicable data protection laws, you have the following rights regarding your personal data held by soju89:

• Right of Access: You may request a copy of all personal data soju89 holds about you. We will provide this information in a commonly used electronic format within 30 days of your verified request.
• Right to Rectification: If any personal data we hold is inaccurate or incomplete, you have the right to request that it be corrected. You can update most information directly via your account settings.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data, subject to legal retention obligations (e.g., AML requirements mandate retention of KYC and transaction data for 5 years after account closure).
• Right to Restrict Processing: You may request that soju89 limit the processing of your data in certain circumstances, such as while we verify the accuracy of disputed data.
• Right to Data Portability: You may request that soju89 provide your personal data in a structured, machine-readable format, or transmit it directly to another service provider where technically feasible.
• Right to Object: You may object to processing of your personal data based on legitimate interests (such as direct marketing). We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on consent (e.g., marketing emails), you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with the subject line "Privacy Rights Request". We may require verification of your identity before processing your request.

soju89 is strictly an adult-only platform. We do not knowingly collect personal information from individuals under the age of 21. If you are under 21, you are prohibited from using soju89 under any circumstances.

If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete that information from our systems and close the associated account. If you believe a minor has provided personal information to soju89, please contact us immediately at [email protected].

soju89 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. The "Last Updated" date at the top of this page indicates when the policy was most recently revised.

Where changes are material and affect your rights, we will make reasonable efforts to notify active users via email or through a prominent notice on the platform. Your continued use of soju89 following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information.

If you have any questions, concerns, or complaints regarding this Privacy Policy or soju89's data handling practices, please contact our Data Protection Officer using the details below:

• Email: [email protected] — Mark your email with the subject line "Privacy Enquiry" or "Data Protection Request" for priority handling.
• Response Time: We aim to respond to all privacy-related enquiries within 5 business days. Complex requests (e.g., subject access requests) may require up to 30 days for full resolution.

If you are not satisfied with our response to a privacy complaint, you have the right to lodge a complaint with the data protection supervisory authority in your jurisdiction.