Privacy Policy

1. Introduction

ink709 ("we", "us", "our", or "the Company") is committed to protecting the privacy and security of every user who accesses our online gaming platform at https://ink709.cam (the "Platform"). This Privacy Policy ("Policy") describes how we collect, use, process, store, share, and safeguard your personal information in connection with your use of our services.

By registering an account with ink709, accessing our Platform, or otherwise using our gaming services — including sports betting, live casino, slot games, and all associated features — you acknowledge that you have read and understood this Policy and consent to the data practices described herein. If you do not consent to these practices, you must cease using our Platform immediately.

This Policy applies to all users of ink709, with particular relevance to residents of Indonesia who form the primary user base of our Platform. Where Indonesian personal data protection principles apply to your usage, we aim to comply with those requirements in addition to the international standards we already maintain.

We may update this Policy periodically to reflect changes in our business practices, technology, or applicable regulations. The "Last Updated" date at the foot of this document indicates when the most recent revision was made. We encourage you to review this Policy regularly.

2. Definitions

Throughout this Policy, the following terms carry the meanings set out below:

• "Personal Data" means any information that, alone or in combination with other information, can be used to identify a natural person directly or indirectly — including your name, email address, date of birth, Indonesian National ID number (NIK), phone number, IP address, and payment details.
• "Processing" refers to any operation performed on Personal Data, whether automated or manual, including collection, recording, storage, alteration, retrieval, consultation, use, disclosure, and deletion.
• "Data Controller" is ink709, which determines the purposes and means by which your Personal Data is processed.
• "Data Processor" refers to a third party that processes Personal Data on our behalf (for example, our payment gateway partners or KYC verification providers).
• "User" or "You" means any person who registers for and uses the ink709 Platform, including Indonesian residents who are the primary intended audience of our services.
• "KYC" (Know Your Customer) refers to our mandatory identity verification process requiring submission of government-issued ID (KTP), proof of address, and a selfie photograph.
• "Cookies" are small data files placed on your device by the ink709 Platform to enable certain functions, remember your preferences, and support analytics.

3. Data We Collect

3.1 Information You Provide Directly

When you create an account, complete KYC verification, make deposits or withdrawals, contact customer support, or participate in promotions, you provide us with Personal Data including but not limited to:

• Registration Data: Full legal name, email address, date of birth, phone number, residential address in Indonesia (city, province, postal code), and preferred currency.
• Identity Documents (KYC): Indonesian National ID card (KTP) image, selfie photograph, proof of address document (utility bill or bank statement from BCA, BRI, BNI, or Mandiri), and any additional documents we may request during enhanced due diligence.
• Financial Data: Bank account details (name, account number, and bank — BCA, BRI, BNI, Mandiri, CIMB Niaga), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay), transaction history, and deposit/withdrawal records.
• Communications: Records of your interactions with our customer support team via live chat, WhatsApp, or email, including the content of those communications.
• Preferences and Settings: Your account configuration, gaming preferences, responsible gaming tool settings (deposit limits, session timers, self-exclusion status), and marketing communication preferences.

3.2 Information Collected Automatically

When you access or use the ink709 Platform, we automatically collect certain technical and behavioral data through cookies, log files, and similar technologies:

• Device & Technical Data: IP address, device type, operating system, browser type and version, screen resolution, language settings, and mobile device identifiers.
• Usage Data: Pages visited, features used, session duration, click patterns, game sessions initiated, bet history, game outcomes, and in-game behavior patterns.
• Location Data: General geographic location derived from your IP address (country, region, city level only — we do not access GPS-level precise location data).
• Performance Data: Error logs, load times, and technical performance metrics used to maintain Platform stability and improve user experience.

3.3 Information from Third Parties

We may receive Personal Data about you from third parties in limited circumstances, including:

• KYC and identity verification service providers who confirm the authenticity of documents you submit.
• Payment processors and banking partners (BCA, BRI, BNI, Mandiri) who confirm transaction status.
• Fraud detection and anti-money laundering (AML) screening services that flag suspicious activity patterns.
• Publicly available sources such as sanctions lists and politically exposed persons (PEP) databases checked as part of our compliance obligations.

4. How We Use Your Personal Data

ink709 processes your Personal Data only for specific, legitimate purposes. The primary purposes for which we use your data are:

4.1 Account Management and Service Delivery

We use your registration and identity data to create and maintain your account, verify your eligibility (age 21+, Indonesian residency), process deposits and withdrawals through your chosen payment methods, provide access to gaming products, and deliver customer support in Indonesian and English.

4.2 Legal Compliance and Fraud Prevention

We are required to verify your identity (KYC) and monitor transactions for potential money laundering, fraud, or other illicit activities. This is a mandatory obligation under international anti-money laundering (AML) and counter-terrorism financing (CTF) standards that our licensing jurisdiction requires us to follow. We may share information with law enforcement authorities where legally compelled to do so.

4.3 Responsible Gaming Compliance

We use your gameplay data, session history, and account behavior to monitor for signs of problem gambling, enforce the deposit and loss limits you set, apply self-exclusion periods you request, and send reality check notifications. These activities are conducted in your interest and form part of our responsible gaming obligations.

4.4 Platform Improvement and Personalization

Aggregated and anonymized usage data helps us understand how players interact with ink709, identify which games and features are most popular among Indonesian users, optimize Platform performance, and develop new features. We may use non-sensitive data to personalize game recommendations and promotional offers within your account.

4.5 Marketing Communications

With your consent, we may send you promotional communications about ink709 offers, new games, seasonal promotions (for example, around Idul Fitri or Indonesian Independence Day on 17 August), and VIP program updates. You may withdraw this consent at any time by contacting our support team or adjusting your account notification settings. We do not send unsolicited marketing to your personal email from third-party advertisers.

5. Data Sharing and Disclosure

ink709 does not sell, rent, or trade your Personal Data to third parties for their own marketing or commercial purposes. We share your data only in the limited circumstances described below:

5.1 Service Providers (Data Processors)

We engage trusted third-party service providers who process Personal Data on our behalf and under our instruction. These include KYC and identity verification platforms, payment processors facilitating bank transfers to and from BCA, BRI, BNI, and Mandiri accounts, customer support software providers, fraud detection services, and cloud infrastructure providers. All service providers are contractually bound to process data only for the purposes we specify and to maintain appropriate security standards.

5.2 Legal and Regulatory Disclosure

We may disclose your Personal Data to regulatory authorities, law enforcement agencies, or other government bodies when required to do so by law, court order, or regulatory directive. We may also disclose information where necessary to protect the legal rights of ink709, prevent fraud, or protect the safety of our users or the public.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of ink709's business assets, your Personal Data may be transferred to the acquiring entity as part of the transferred assets. We will notify you of any such transfer and the applicable privacy terms of the new entity before your data becomes subject to a different privacy policy.

5.4 Game Providers

Our Platform integrates games from third-party studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, and Pocket Games Soft. These providers may receive limited technical data (such as a pseudonymous player identifier and session token) necessary to operate their games within our Platform. They do not receive your full name, KYC documents, or banking details.

6. Data Retention

We retain your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, accounting, or reporting obligations. The following general retention periods apply:

• Account and Registration Data: Retained for the lifetime of your account and for a minimum of five (5) years following account closure, as required by our anti-money laundering compliance obligations.
• KYC and Identity Documents: Retained for a minimum of five (5) years from the date of submission or from the date your account is closed, whichever is later.
• Transaction Records: All deposit, withdrawal, and betting transaction records are retained for a minimum of five (5) years in accordance with international AML standards.
• Customer Support Communications: Retained for two (2) years from the date of the interaction unless a longer period is required for ongoing dispute resolution.
• Marketing Consent Records: Retained for as long as you hold an active account and for one (1) year following account closure or withdrawal of consent.
• Technical and Usage Logs: Typically retained for twelve (12) months, after which they are aggregated or anonymized for analytics purposes.

When Personal Data is no longer required for its original purpose and no legal obligation compels further retention, we securely delete or anonymize it so that it can no longer be linked to you.

7. Security Measures

ink709 implements a comprehensive set of technical and organizational security measures designed to protect your Personal Data against unauthorized access, accidental loss, alteration, disclosure, or destruction. Our security framework includes:

• Transport Layer Security (TLS/SSL): All data transmitted between your browser or device and our Platform is encrypted using 256-bit SSL/TLS encryption, the same standard used by major international banks.
• Data Encryption at Rest: Sensitive data stored in our databases — including KYC documents and payment details — is encrypted at rest using industry-standard AES-256 encryption.
• Access Controls: Access to systems holding Personal Data is restricted to authorized personnel on a strict need-to-know basis. All staff with data access are subject to confidentiality obligations and regular security training.
• Two-Factor Authentication (2FA): We offer 2FA for user accounts and enforce it for all internal administrative access to systems holding user data.
• Regular Security Audits: Our Platform undergoes periodic independent security assessments, penetration testing, and vulnerability scans conducted by qualified third-party security firms.
• Incident Response: We maintain 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 users without undue delay.

8. Cookies and Tracking Technologies

8.1 What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They allow the site to recognize your device on subsequent visits, remember your preferences, and collect usage data. ink709 uses cookies and similar technologies (such as web beacons and local storage) to operate and improve our Platform.

8.2 Categories of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in and security cookies that prevent cross-site request forgery. These cannot be disabled without breaking core Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, account display options, and responsible gaming tool configurations. Disabling these cookies may affect your experience but will not prevent you from using the Platform.
• Analytics Cookies: Help us understand how users interact with ink709 by collecting aggregated data on page views, session duration, and feature usage. This data is used solely to improve the Platform and is never used to identify you personally in marketing contexts.
• Performance Cookies: Monitor Platform speed, uptime, and technical error rates to help our engineering team maintain service quality.

8.3 Managing Cookies

You can control and manage cookies through your browser settings. Most modern browsers allow you to block, delete, or receive notifications when cookies are set. Please note that disabling strictly necessary cookies will impair your ability to use the ink709 Platform, as features such as login sessions depend on them. Refer to your browser's help documentation for instructions on managing cookie preferences.

9. Your Data Rights

As a user of ink709, you have the following rights with respect to your Personal Data. We will respond to verified requests within a reasonable timeframe, typically within 30 days:

• 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: If any Personal Data we hold is inaccurate or incomplete, you may request that we correct or update it. You may also update certain information directly through your account settings.
• Right to Erasure: You may request deletion of your Personal Data in certain circumstances — for example, where it is no longer necessary for the purposes for which it was collected. Note that we cannot delete data we are legally required to retain, such as transaction records and KYC documents subject to AML retention obligations.
• Right to Restriction of Processing: You may request that we restrict processing of your Personal Data in specific circumstances, such as while a dispute about its accuracy is being resolved.
• Right to Data Portability: Where technically feasible and legally applicable, you may request a copy of the Personal Data you provided to us in a commonly used, machine-readable format.
• Right to Withdraw Consent: Where processing is based on your consent (for example, for marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Right to Object: You may object to certain types of processing, including any direct marketing activities or processing based on our legitimate interests where your fundamental rights and freedoms override those interests.

To exercise any of these rights, please contact our support team at [email protected] with the subject line "Data Rights Request". We may need to verify your identity before processing your request to protect against unauthorized data access.

10. Protection of Minors

ink709 strictly prohibits use of our Platform by individuals under 21 years of age. Our services are intended exclusively for adults (21+) in accordance with responsible gaming standards applicable to the Indonesian market. We do not knowingly collect Personal Data from anyone under 21.

If we discover or have reason to believe that a user is under 21, we will immediately suspend that account, investigate the matter, and permanently close the account if the age violation is confirmed. Any funds deposited by an underage user will be returned to the originating payment method after deducting any administrative processing costs incurred.

Parents and guardians are encouraged to use parental control and internet filtering software to prevent minors from accessing online gambling platforms. If you believe a minor has registered an account with ink709, please contact us immediately at [email protected] so we can take appropriate action.

11. International Data Transfers

ink709 operates as an internationally licensed gaming platform. Your Personal Data may be transferred to and processed in countries outside Indonesia, including the jurisdiction where our servers and licensed operations are based. These countries may have data protection laws that differ from those in Indonesia.

Where we transfer Personal Data internationally, we apply appropriate safeguards to ensure your data receives a level of protection consistent with this Policy. These safeguards may include contractual clauses with our service providers that obligate them to protect the data to the same standard we apply, or reliance on the service provider's certified compliance with recognized international security frameworks.

By using the ink709 Platform, you acknowledge and consent to the transfer of your Personal Data to processing locations outside Indonesia where necessary to deliver our services, subject always to the protections described in this Policy.

12. Updates to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or Platform features. When we make material changes, we will update the "Last Updated" date at the bottom of this page and, where appropriate, notify registered users by email or through an in-account notification.

We encourage you to review this Policy periodically to stay informed about how ink709 protects your information. Your continued use of our Platform following the posting of changes constitutes your acceptance of those changes. If you disagree with any updated terms, you should cease using our services and may request account closure by contacting our support team.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or the way ink709 handles your Personal Data, please reach out to us through any of the following channels: