Privacy Policy — spn88

spn88 operates a licensed online betting and gaming platform serving the Indonesian market. In the course of providing sports betting, live casino, togel (Indonesia's traditional numbers lottery), and slot gacor (high-payout slot) products to our Members, we necessarily collect and process certain personal data.

We take our obligations in respect of personal data seriously. This Privacy Policy is written in plain language to ensure that every spn88 Member — regardless of their familiarity with data protection law — can understand exactly how their information is handled. Where technical or legal terms are unavoidable, we define them clearly.

This policy is intended to be read alongside spn88's Terms & Conditions. In the event of any inconsistency between this policy and the Terms & Conditions on a data protection matter, this Privacy Policy takes precedence.

If you have questions about any aspect of this policy, or wish to exercise any of the rights described in Section 11, please contact spn88 using the details provided in Section 16.

The following terms have the meanings set out below throughout this Privacy Policy:

• "Personal Data" means any information that relates to an identified or identifiable natural person — that is, information from which a living individual can be directly or indirectly identified.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, and deletion.
• "Data Controller" means spn88, the entity that determines the purposes and means of Processing Personal Data collected via the platform.
• "Data Processor" means a third party that Processes Personal Data on spn88's behalf under a contractual data-processing agreement, such as a KYC verification provider or payment gateway.
• "Member" means an individual who has completed account registration on the spn88 platform and whose account remains active.
• "KYC" means Know Your Customer — the identity verification process required prior to withdrawal processing, as described in the Terms & Conditions.
• "Cookie" means a small text file placed on your device by the platform to store preference, session, or analytics information.

spn88 collects the following categories of personal data, depending on your interactions with the platform:

spn88 does not collect sensitive personal data categories such as racial or ethnic origin, political opinions, religious beliefs, biometric data, or health data, except where voluntarily disclosed by a Member in the context of a responsible gaming self-exclusion or health-related account restriction request.

spn88 collects personal data through the following channels:

• Direct submission: Data you provide when completing the registration form, submitting KYC documents, initiating a deposit or withdrawal, contacting customer support, or responding to promotions.
• Automated technical collection: IP addresses, device identifiers, browser data, and session-level usage information are collected automatically via platform infrastructure logs whenever you access spn88, whether or not you are logged in.
• Cookies and tracking technologies: The platform uses first-party cookies to maintain your login session, store your language and display preferences, and measure aggregate platform performance. See Section 10 for full details.
• Third-party verification providers: When you submit KYC documents, spn88 may share those documents with a licensed identity verification service provider. That provider may return enriched data (such as a liveness-check result) that spn88 stores as part of your verification record.
• Payment processors: When a deposit or withdrawal is processed via BCA, BRI, BNI, Mandiri, or an e-wallet provider, spn88 receives confirmation data from that provider, including transaction reference numbers, timestamps, and the account name associated with the transaction.

spn88 uses the personal data it holds for the following purposes:

1. Account management: Creating, maintaining, and securing your spn88 Account; authenticating your identity at login; processing password resets and account-recovery requests.
2. Transaction processing: Accepting deposits from BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, and cryptocurrency wallets; processing withdrawal requests to verified payment methods; maintaining accurate balance records.
3. KYC and fraud prevention: Verifying your identity before approving withdrawals; detecting and preventing fraudulent transactions, money laundering, and abuse of promotional offers; monitoring for suspicious activity patterns.
4. Customer support: Responding to your enquiries via live chat, email, and WhatsApp; resolving disputes; escalating formal complaints to the compliance team.
5. Legal and regulatory compliance: Meeting record-keeping obligations under applicable licensing requirements; responding to lawful requests from regulatory authorities or law enforcement agencies.
6. Platform improvement: Analysing aggregated, anonymised usage data to identify performance issues, improve user experience, and prioritise development of new features requested by Indonesian members.
7. Responsible gaming: Monitoring betting patterns to identify Members who may be displaying signs of problem gambling, in order to proactively offer responsible gaming tools as described in our Responsible Gaming policy.
8. Marketing communications: Sending you promotional offers, bonus notifications, and platform updates via your registered email address or WhatsApp number — but only if you have opted in to receive such communications. You may opt out at any time by contacting support.

spn88 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between spn88 and you as a Member — including account creation, payment processing, and KYC verification — is necessary to deliver the services you have requested.
• Legal obligation: Processing required to comply with applicable laws, licensing conditions, and lawful regulatory or law enforcement requests, including anti-money-laundering (AML) and counter-terrorism financing (CTF) obligations.
• Legitimate interests: Processing carried out to pursue spn88's legitimate business interests where those interests are not overridden by your rights — including fraud prevention, platform security, responsible gaming monitoring, and aggregate usage analytics.
• Consent: Processing for marketing communications and optional analytics programmes, where consent is the chosen legal basis. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

spn88 does not sell, rent, or otherwise transfer your personal data to unaffiliated third parties for their own commercial purposes. We may share your data with the following categories of recipients, strictly as necessary:

• Payment processors: BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, LinkAja, and cryptocurrency gateway providers — solely to execute deposit and withdrawal transactions you have initiated.
• Identity verification providers: Licensed KYC and AML service providers who assist spn88 in verifying Member identities before withdrawal approval. These providers are bound by data-processing agreements and may not use your data for any purpose other than verification.
• IT infrastructure providers: Cloud hosting, content delivery, and database management providers who process data on spn88's servers. All such providers operate under data-processing agreements that restrict their use of the data.
• Regulatory authorities and law enforcement: Where required by applicable law, court order, or licensing obligation, spn88 will disclose personal data to the relevant authority. Where legally permitted, spn88 will notify the affected Member before making such a disclosure.
• Fraud prevention networks: Anonymised or pseudonymised fraud signals may be shared with industry fraud prevention platforms to protect spn88 and its Members from organised fraud schemes.

In all cases where data is shared with a third party, spn88 ensures that appropriate contractual safeguards are in place and that the third party is bound to process the data only for the specified purpose.

spn88's primary data processing infrastructure is located within the Asia-Pacific region. Some service providers — particularly those providing cloud infrastructure, identity verification, or fraud prevention services — may be located in jurisdictions outside Indonesia.

Where personal data is transferred internationally, spn88 ensures that adequate protections are in place, including:

• Contractual data-processing agreements incorporating internationally recognised standard contractual clauses;
• Transfer to jurisdictions that offer an adequate level of data protection as assessed by relevant international standards; or
• Other legally recognised transfer mechanisms appropriate to the circumstances.

You may request information about the specific safeguards in place for any particular international transfer by contacting spn88 using the details in Section 16.

spn88 retains personal data for the following periods, unless a longer retention period is required by law:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised such that it can no longer be associated with any identifiable individual.

spn88 uses first-party cookies to enhance your experience on the platform. We do not use third-party advertising cookies or cross-site tracking technologies. The cookies we set fall into the following categories:

• Strictly necessary cookies: Required for the platform to function correctly. These include session authentication tokens that keep you logged in and security tokens that protect against cross-site request forgery. These cookies cannot be disabled without preventing you from using the platform.
• Preference cookies: Store your display preferences, such as your chosen timezone (defaulting to WIB, UTC+7) and notification settings. Disabling these cookies will cause your preferences to reset on each visit.
• Analytics cookies: Collect anonymised, aggregated data about how Members navigate the platform, which pages are visited most, and where technical errors occur. This data is used solely to improve platform performance and is never linked back to individual Members. You may opt out of analytics cookies at any time by contacting support.

You can control cookie behaviour through your browser settings. Note that disabling strictly necessary cookies will impair your ability to access authenticated areas of the platform.

As a Member of spn88, you hold the following rights in respect of the personal data we process about you. To exercise any of these rights, please contact spn88 using the details in Section 16. spn88 will respond within 30 calendar days of receiving a verifiable request.

The spn88 platform is strictly prohibited for use by persons under the age of 21. spn88 does not knowingly collect personal data from individuals under 21 years of age. If you are a parent or guardian and believe that your child has registered an account or provided personal data to spn88, please contact us immediately using the details in Section 16.

Upon receiving such a notification, spn88 will promptly investigate, close any confirmed underage account, delete the associated personal data, and — where applicable — return any funds to the originating payment method after verification of ownership.

spn88 implements a multi-layered security framework to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Key measures include:

• Encryption in transit: All data transmitted between your device and spn88 servers is encrypted using TLS 1.2 or higher, with 256-bit symmetric encryption.
• Encryption at rest: Sensitive data fields — including payment details, identity document references, and authentication credentials — are encrypted in the database using AES-256.
• Access controls: Access to personal data within spn88's systems is restricted on a need-to-know basis. Staff members are granted access only to the data categories required for their specific role, and all access events are logged.
• Two-factor authentication: Available to all Members for Account access; mandatory for staff with administrative system access.
• Penetration testing: spn88 commissions independent security assessments on a regular schedule to identify and remediate vulnerabilities before they can be exploited.
• Incident response: spn88 maintains a documented data breach response procedure. In the event of a confirmed breach affecting Member personal data, affected individuals will be notified within 72 hours.

While spn88 takes all commercially reasonable precautions, no online platform can guarantee absolute security. You are responsible for maintaining the security of your own device and login credentials, including enabling two-factor authentication on your Account.

The spn88 platform may reference third-party services such as game studio providers (Pragmatic Play, Evolution Gaming, PG Soft) or payment networks (BCA, BRI, BNI, Mandiri). While spn88 selects these partners carefully, each third party operates under its own privacy policy.

spn88 accepts no responsibility for the privacy practices of any third-party service. We recommend that you review the privacy policy of any third-party service you interact with independently of spn88.

spn88 reserves the right to update this Privacy Policy at any time to reflect changes in data protection law, regulatory requirements, platform functionality, or business practices.

Where changes are material — that is, where they significantly affect how your personal data is processed or your rights in relation to it — spn88 will notify you by email to your registered address at least 14 days before the changes take effect. For non-material changes (such as typographic corrections or clarifications that do not alter substance), we may update the policy without prior notice.

The current version of this Privacy Policy is always accessible at https://spn88.cam/privacy-policy. The "Last Updated" date at the top of the document reflects the date of the most recent revision. Your continued use of the platform after the effective date of any revision constitutes your acceptance of the updated policy.

For all privacy-related enquiries — including rights requests, data breach reports, concerns about how your data is processed, or questions about this Privacy Policy — please contact spn88 using the details below. All contact information is provided as plain text and is not a clickable link.