Privacy Policy

1. Introduction

Welcome to the pg389 Privacy Policy. This document governs the collection, use, storage, and disclosure of personal information provided by users of the pg389 online gaming platform (the "Platform"), accessible at https://pg389.cam and through any associated mobile or desktop applications.

pg389 is committed to protecting the privacy and security of your personal data in accordance with internationally recognized data protection principles. We process your information transparently, lawfully, and only to the extent necessary to provide you with our services, comply with legal obligations, and protect the legitimate interests of our business and our users.

By registering an account on pg389 or using our Platform in any capacity, you acknowledge that you have read, understood, and agreed to the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use our Platform or provide us with any personal information.

2. Data Controller

pg389 operates as the data controller responsible for the personal information you provide through the Platform. As data controller, we determine the purposes for which and the manner in which your personal data is processed. We are accountable for ensuring that data processing activities comply with applicable data protection laws and regulations.

For the purposes of this Privacy Policy, the data controller is the legal entity operating pg389 under its international gaming license. All inquiries regarding data processing, privacy rights, or data protection concerns should be directed to our Data Protection Officer using the contact details provided in Section 14 of this Policy.

3. What Data We Collect

pg389 collects various categories of personal information to operate the Platform effectively, comply with regulatory requirements, and provide you with a secure gaming experience. The types of data we collect include:

3.1 Information You Provide Directly

• Registration Information: When you create an account, we collect your full name, date of birth, email address, mobile phone number, residential address, and preferred currency (IDR).
• Identity Verification (KYC) Documents: To comply with anti-money-laundering regulations and verify your age (21+ requirement), we collect copies of your Indonesian National Identity Card (KTP), proof of address documents, and selfie verification photographs.
• Financial Information: Bank account details, e-wallet account identifiers (for BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay), transaction history, deposit and withdrawal records, and balance information.
• Communication Data: Any correspondence you send to our customer support team via live chat, email, WhatsApp, or other communication channels, including complaint records and support ticket history.
• Marketing Preferences: Your consent or objection to receiving promotional emails, SMS messages, or other marketing communications from pg389.

3.2 Information Collected Automatically

• Device and Browser Information: IP address, device type (mobile, tablet, desktop), operating system, browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited, features accessed, time spent on the Platform, clickstream data, referring and exit pages, and search queries within the Platform.
• Gaming Activity: Bet history, game types played (slots, live casino, sports betting, togel), wagering amounts, winnings and losses, bonus claims and usage, and timestamps of gaming sessions.
• Location Information: Approximate geographic location derived from your IP address to ensure compliance with geographic restrictions and to provide localized services.
• Cookies and Tracking Technologies: Information collected through cookies, web beacons, and similar technologies as detailed in Section 10 of this Policy.

3.3 Information from Third Parties

• Payment Processors: Transaction confirmation data from banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay) to verify deposits and withdrawals.
• Game Providers: Technical data and game outcome information from our licensed game suppliers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, and others) to maintain accurate gaming records.
• Fraud Prevention Services: Data from third-party fraud detection and risk management tools used to identify suspicious activity and protect the integrity of the Platform.

4. How We Use Your Data

pg389 processes your personal information for specific, legitimate purposes directly related to operating our Platform and complying with our legal obligations. The primary purposes for which we use your data include:

4.1 Account Management and Service Provision

• Creating and maintaining your user account on the Platform.
• Authenticating your identity when you log in to the Platform.
• Processing deposits, withdrawals, and other financial transactions.
• Crediting bonuses, free spins, cashback, and loyalty rewards to your account.
• Providing customer support and responding to your inquiries.
• Facilitating participation in casino games, sports betting markets, and lottery-style games including togel.

4.2 Legal and Regulatory Compliance

• Verifying that you are at least 21 years of age and legally eligible to access the Platform.
• Conducting Know Your Customer (KYC) and Customer Due Diligence (CDD) checks to prevent money laundering, fraud, and terrorist financing.
• Detecting and preventing underage gambling, multiple account abuse, collusion, and other prohibited conduct.
• Complying with record-keeping requirements under applicable gaming regulations and financial crime legislation.
• Responding to lawful requests from regulatory authorities, law enforcement agencies, or courts of competent jurisdiction.

4.3 Security and Fraud Prevention

• Monitoring account activity for signs of unauthorized access, hacking attempts, or fraudulent behavior.
• Implementing risk-based transaction monitoring to identify unusual deposit or withdrawal patterns.
• Protecting the Platform from cyberattacks, distributed denial-of-service (DDoS) attacks, and other security threats.
• Investigating suspected breaches of our Terms & Conditions or applicable laws.

4.4 Platform Improvement and Personalization

• Analyzing usage patterns to improve Platform functionality, user interface design, and overall user experience.
• Developing new features, games, and services based on player preferences and feedback.
• Personalizing game recommendations, bonus offers, and promotional content based on your gaming history and preferences (with your consent where required).
• Conducting A/B testing and performance optimization of Platform features.

4.5 Marketing and Communication

• Sending you service-related notifications such as account verification emails, withdrawal confirmations, and security alerts.
• Communicating promotional offers, new game releases, tournament invitations, and exclusive bonuses (only with your consent, which you may withdraw at any time).
• Conducting customer satisfaction surveys and research to better understand player needs.

5. Legal Basis for Processing

pg389 processes your personal data only where we have a valid legal basis to do so under applicable data protection law. Our legal bases for processing include:

• Contractual Necessity: Processing is necessary to perform our contract with you (the Terms & Conditions you accepted when registering), including providing gaming services, processing transactions, and maintaining your account.
• Legal Obligation: Processing is required to comply with legal obligations imposed on us, such as KYC/AML verification, age verification (21+ requirement), record-keeping for regulatory audits, and responding to lawful requests from authorities.
• Legitimate Interests: Processing is necessary for our legitimate business interests or those of a third party, provided your rights and freedoms do not override those interests. Examples include fraud prevention, security monitoring, Platform improvement, and marketing to existing customers where permitted.
• Consent: For certain processing activities (such as optional marketing communications or non-essential cookies), we rely on your explicit, freely-given consent, which you may withdraw at any time without affecting the lawfulness of processing based on consent before its withdrawal.

6. Data Sharing and Disclosure

pg389 does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your data with carefully selected third parties in the following limited circumstances:

6.1 Service Providers

We engage trusted third-party service providers to perform functions on our behalf, including:

• Payment Processors: Banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay) to facilitate deposits and withdrawals.
• Game Suppliers: Licensed software providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming) who deliver casino games, live dealer tables, and sports betting platforms.
• Identity Verification Services: Third-party KYC/AML screening providers who assist with identity document verification and fraud detection.
• Cloud Hosting Providers: Secure data centers and cloud infrastructure providers that host our Platform and store data backups.
• Customer Support Tools: Live chat, email management, and ticketing systems used by our support team to assist you.

All service providers are contractually bound to process your data only on our instructions, to implement appropriate security measures, and to comply with applicable data protection laws.

6.2 Legal and Regulatory Authorities

We may disclose your personal information to regulatory bodies, law enforcement agencies, courts, or other governmental authorities where required by law or where necessary to:

• Comply with a legal obligation, court order, or valid legal process.
• Enforce our Terms & Conditions or other agreements.
• Protect the rights, property, or safety of pg389, our users, or the public.
• Respond to claims that content on the Platform violates the rights of third parties.
• Investigate or prevent fraud, money laundering, or other illegal activity.

6.3 Business Transfers

In the event of a merger, acquisition, asset sale, or other corporate restructuring involving pg389, your personal information may be transferred to the acquiring entity, subject to the same privacy protections outlined in this Policy.

6.4 With Your Consent

We may share your information with other third parties where you have provided explicit consent to do so.

7. Data Security Measures

pg389 employs industry-standard technical and organizational measures to protect your personal data from unauthorized access, accidental loss, destruction, or damage. Our security framework includes:

• Encryption: All data transmitted between your device and our servers is protected by 256-bit SSL (Secure Socket Layer) encryption, the same technology used by banks and financial institutions worldwide.
• Secure Data Storage: Personal information is stored on secure servers located in certified data centers with physical access controls, surveillance, and environmental protection systems.
• Access Controls: Access to personal data is restricted to authorized employees and contractors on a need-to-know basis. All personnel with access to personal data are bound by confidentiality obligations.
• Two-Factor Authentication: We offer optional two-factor authentication (2FA) for account logins to add an additional layer of security.
• Regular Security Audits: Our Platform undergoes periodic penetration testing, vulnerability assessments, and security audits conducted by independent third-party cybersecurity firms.
• Incident Response: We maintain a documented data breach response plan to ensure rapid detection, containment, and notification in the unlikely event of a security incident.
• Employee Training: All staff members receive regular training on data protection principles, security best practices, and their obligations under this Privacy Policy.

While we implement robust security measures, please be aware that no method of transmission over the Internet or electronic storage is 100% secure. You also have a responsibility to protect your account by choosing a strong password and keeping your login credentials confidential.

8. Data Retention

pg389 retains your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our data retention periods are determined based on the following criteria:

When personal data is no longer required, it is securely deleted or anonymized in accordance with our data destruction procedures. Anonymized data (from which you cannot be identified) may be retained indefinitely for statistical analysis and research purposes.

9. Your Privacy Rights

Depending on your jurisdiction, you may have certain rights regarding your personal data. At pg389, we respect and facilitate the exercise of the following privacy rights:

• Right of Access: You have the right to request confirmation of whether we process your personal data and to obtain a copy of that data, along with information about how and why it is processed.
• Right to Rectification: If you believe any personal information we hold about you is inaccurate or incomplete, you have the right to request correction or completion of that data.
• Right to Erasure ("Right to be Forgotten"): In certain circumstances, you may request deletion of your personal data, subject to legal retention requirements and legitimate business needs.
• Right to Restriction of Processing: You may request that we limit the processing of your personal data in specific situations, such as while we verify the accuracy of disputed data.
• Right to Data Portability: Where technically feasible, you have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit that data to another controller.
• Right to Object: You may object to processing of your personal data based on legitimate interests or for direct marketing purposes. We will cease such processing unless we have compelling legitimate grounds to continue.
• 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 based on consent before withdrawal.
• Right to Lodge a Complaint: If you believe we have not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with your local data protection authority.

To exercise any of these rights, please contact our Data Protection Officer using the details provided in Section 14. We will respond to your request within 30 calendar days and may require verification of your identity before processing your request.

10. Cookies and Tracking Technologies

pg389 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver personalized content. A cookie is a small text file stored on your device that helps us recognize you on subsequent visits.

10.1 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function properly, including session management, security features, and account authentication. These cannot be disabled.
• Performance Cookies: Collect anonymous information about how visitors use the Platform, which pages are most popular, and whether users encounter errors. This helps us improve Platform performance.
• Functionality Cookies: Remember your preferences (such as language, currency, and display settings) to provide a more personalized experience.
• Analytics Cookies: Used to understand user behavior and measure the effectiveness of our content and features through aggregated statistics.

10.2 Managing Cookies

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. Please note that disabling certain cookies may limit your ability to use some features of the Platform. You can manage your cookie preferences through your browser settings or by using the cookie consent tool provided on first visit to the Platform.

11. International Data Transfers

pg389 operates internationally, and your personal data may be transferred to, stored, and processed in countries outside Indonesia, including jurisdictions that may not provide the same level of data protection as Indonesian law. When we transfer your data internationally, we implement appropriate safeguards to ensure your data remains protected, including:

• Transferring data only to countries recognized as providing adequate protection under applicable data protection laws.
• Entering into Standard Contractual Clauses (as approved by relevant data protection authorities) with third-party recipients.
• Ensuring that service providers maintain appropriate technical and organizational security measures.

By using the pg389 Platform, you acknowledge and consent to the international transfer of your personal data as described in this Policy.

12. Minors and Age Verification

pg389 strictly prohibits the use of the Platform by individuals under the age of 21. We do not knowingly collect personal information from minors. All users are required to complete mandatory age verification (KYC) by submitting valid Indonesian National Identity Card (KTP) documentation before withdrawal privileges are granted.

If we discover that personal information has been collected from an individual under 21 years of age, we will immediately close the account, void any transactions, and delete the associated data from our systems. Parents or guardians who believe their child has provided personal information to pg389 should contact us immediately at [email protected].

13. Changes to This Privacy Policy

pg389 reserves the right to update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or business operations. Material changes will be communicated to registered users via email and/or a prominent notice on the Platform at least 14 days before the changes take effect.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data. The "Effective Date" at the top of this Policy indicates when it was last revised. Your continued use of the Platform after changes become effective constitutes your acceptance of the revised Privacy Policy.

14. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact our Data Protection Officer:

• Email: [email protected] (Subject line: "Privacy Inquiry")
• Live Chat: Available 24/7 through the pg389 Platform
• Response Time: Privacy-related inquiries are prioritized and typically receive a response within 48 hours (business days, WIB).

For complaints or concerns that cannot be resolved through our internal process, you have the right to contact your local data protection supervisory authority.