Privacy Policy — naga89

1. Definitions

For the purposes of this Privacy Policy, the following terms carry the meanings assigned below:

• "Personal Data" means any information that identifies or could reasonably be used to identify you as a natural person, including your name, national identity number, email address, bank account number, IP address, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, and deletion.
• "Controller" means naga89, the entity that determines the purposes and means of Processing your Personal Data.
• "Processor" means a third party that Processes Personal Data on behalf of naga89 under a data processing agreement.
• "KYC Data" means identity and address verification documents submitted during the Know Your Customer verification process.
• "Cookies" means small text files placed on your device by the Platform to enable functionality, measure performance, and personalize your experience.
• "Sensitive Personal Data" means Personal Data revealing racial or ethnic origin, religious or philosophical beliefs, health data, or financial account credentials — categories that attract heightened protection under applicable data protection law.

2. Personal Data We Collect

2.1 Account Registration Data

When you register an Account on naga89, we collect the following information:

• Full legal name (as shown on your Indonesian national identity card, KTP, or passport).
• Date of birth (to verify that you are at least 21 years of age).
• Indonesian residential address.
• Email address and mobile phone number.
• Username and encrypted password.
• Preferred language and currency (IDR).

2.2 KYC and Verification Data

Before processing your first Withdrawal, we collect:

• Photographs or scans of your government-issued identity document (KTP or passport).
• A selfie photograph of you holding your identity document.
• Proof of address documents (utility bills, bank statements, or government letters issued within the past 3 months).
• Bank account details (account holder name, bank name, and account number) registered in your own name at BCA, BRI, BNI, Mandiri, CIMB Niaga, or OCBC NISP.
• E-wallet identifiers for OVO, DANA, GoPay, ShopeePay, or LinkAja accounts registered in your own name.

2.3 Transaction Data

Each time you conduct a financial transaction, we record:

• Deposit and Withdrawal amounts, timestamps, and payment method used.
• Betting history, including markets selected, stake amounts, odds, and settlement results.
• Bonus credits claimed, wagering progress, and Bonus settlement outcomes.
• Account balance history.

2.4 Technical and Device Data

When you access naga89, we automatically collect certain technical data:

• IP address and approximate geolocation (country and city level).
• Device type, operating system, and browser version.
• Session timestamps, pages viewed, and features used.
• Referral source (the URL or search engine that directed you to naga89).
• Cookie identifiers and local storage data (see Section 10).

2.5 Customer Support Data

When you contact our customer support team via live chat or email, we collect the content of your communications, including any Personal Data you voluntarily share in the course of resolving your query. Support interactions are recorded and retained for quality assurance and training purposes.

3. How We Collect Your Data

We collect Personal Data through the following channels:

• Directly from you — when you register, complete KYC, make deposits or Withdrawals, contact support, or respond to promotions.
• Automatically — through Cookies, web beacons, server logs, and analytics tools when you browse the Platform.
• From third-party service providers — including KYC verification services, payment processors (bank APIs and e-wallet providers), fraud detection platforms, and sports data feed providers.

4. Purposes of Processing Your Data

We use your Personal Data for the following clearly defined purposes:

5. Legal Basis for Processing

We process your Personal Data on one or more of the following legal bases:

• Contractual necessity: Processing is required to perform our obligations under the Terms and Conditions you accepted when registering — including maintaining your Account, processing financial transactions, and providing betting services.
• Legal obligation: We are required by applicable law and regulation to process certain categories of Personal Data — including KYC verification, AML transaction monitoring, and financial record-keeping.
• Legitimate interests: We process technical and device data for fraud prevention, platform security, and product improvement, where our legitimate interests are not overridden by your privacy rights.
• Consent: Where we send marketing communications or use non-essential Cookies, we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without penalty.

6. Data Sharing and Disclosure

6.1 Third-Party Service Providers

naga89 engages carefully vetted third-party Processors to assist in delivering our services. These include:

• Payment processors: Indonesian bank APIs and e-wallet platforms (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, OVO, DANA, GoPay, ShopeePay, LinkAja) receive transaction data strictly necessary to complete deposit and Withdrawal operations.
• KYC verification providers: Identity document scanning and liveness detection services receive your KYC Data to perform automated and manual verification checks.
• Fraud and risk platforms: Device fingerprinting and behavioral analytics providers receive technical and session data to detect and prevent fraudulent activity.
• Cloud infrastructure providers: Servers and databases hosting Platform data are operated by internationally recognized cloud providers under binding data processing agreements.
• Customer support platforms: Live chat and ticketing systems used by our support team may store conversation transcripts within their infrastructure under strict confidentiality agreements.

All third-party Processors are contractually bound to process your Personal Data only as instructed by naga89, to maintain appropriate security standards, and not to use your data for their own independent purposes.

6.2 Legal and Regulatory Disclosure

We may disclose your Personal Data to law enforcement agencies, regulatory bodies, or other government authorities when we are legally compelled to do so — for example, in response to a valid court order, a regulatory inquiry, or an anti-money-laundering investigation. We will notify you of such disclosures where we are legally permitted to do so.

6.3 Business Transfers

In the event that naga89 undergoes a merger, acquisition, or sale of assets, your Personal Data may be transferred to the acquiring entity as part of that transaction. You will be notified prior to any such transfer, and the receiving entity will be required to honor the commitments made in this Policy.

7. International Data Transfers

naga89 operates internationally, and your Personal Data may be stored on or transferred to servers located outside Indonesia. When we transfer Personal Data outside of Indonesia, we implement appropriate safeguards to ensure that your data receives a level of protection consistent with applicable data protection principles. These safeguards include standard contractual clauses, data processing agreements with appropriate security standards, and — where applicable — transfers only to jurisdictions recognized as providing adequate data protection.

By using naga89, you acknowledge and consent to the transfer of your Personal Data to servers or service providers located outside Indonesia where necessary for the provision of our services.

8. Data Retention

We retain your Personal Data for as long as is necessary to fulfill the purposes described in this Policy and to comply with our legal obligations. Specific retention periods are as follows:

Once a retention period expires, Personal Data is securely deleted or anonymized in a manner that prevents re-identification. Where data is retained in anonymized form for statistical or research purposes, it is no longer considered Personal Data and falls outside the scope of this Policy.

9. Security Measures

naga89 implements a multi-layered security framework to protect your Personal Data from unauthorized access, disclosure, alteration, or destruction. Our technical and organizational security measures include:

• Encryption: All data in transit is protected by TLS 1.3. All data at rest is encrypted using AES-256 encryption. Password hashes use bcrypt with a minimum cost factor of 12.
• Access controls: Personal Data is accessible only to naga89 staff who require it to perform their job functions. Access is governed by role-based permissions, multi-factor authentication, and regular access reviews.
• Network security: Our infrastructure is protected by firewalls, intrusion detection systems, and DDoS mitigation services. Regular penetration testing is conducted by independent security specialists.
• Secure development practices: Our engineering team follows OWASP security guidelines. Code changes undergo security review before deployment to production.
• Incident response: We maintain a documented security incident response plan. In the event of a breach affecting your Personal Data, we will notify you within 72 hours of discovery.
• Employee training: All staff handling Personal Data complete mandatory data protection and security training upon onboarding and on an annual basis thereafter.

10. Cookies and Tracking Technologies

10.1 What Are Cookies

Cookies are small text files placed on your device when you visit naga89. They allow the Platform to recognize your device, remember your preferences, keep you logged in, and collect usage statistics. Similar technologies — including web beacons, pixel tags, and local storage — serve comparable functions.

10.2 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 tokens that protect against CSRF attacks. These cookies cannot be disabled.
• Functional cookies: Remember your preferences such as display language and odds format. Disabling these may affect your experience but will not prevent core functionality.
• Analytics cookies: Collect anonymized usage data to help us understand how Players navigate the Platform, which features are most used, and where errors occur. We use this data to improve naga89's design and performance.
• Marketing cookies: Track your interaction with promotional content and help us serve relevant offers. These are only placed with your explicit consent.

10.3 Managing Cookies

You can control non-essential cookies through your browser settings. Most modern browsers allow you to view, block, or delete cookies. Please note that disabling cookies may impair certain features of naga89, including persistent login and personalized content. For detailed instructions on managing cookies in your browser, refer to your browser's help documentation.

11. Minors and Age Restrictions

naga89 is strictly intended for adults aged 21 years or older. We do not knowingly collect Personal Data from individuals under 21. If you are under 21, you must not register an Account or use the Platform in any capacity.

If we discover or are notified that we have inadvertently collected Personal Data from a person under 21, we will immediately close that Account, delete all associated Personal Data, and refund any deposited funds (less any Bonuses) to the registered payment method. If you believe a minor has registered on naga89, please contact us immediately at [email protected].

12. Your Data Subject Rights

Subject to applicable data protection law, you have the following rights with respect to your Personal Data held by naga89:

• Right of access: You may request a copy of the Personal Data we hold about you, along with information about how it is used and with whom it is shared.
• Right to rectification: You may request that we correct any inaccurate or incomplete Personal Data. For Account details, you can update most information directly in your Account settings.
• Right to erasure ("right to be forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations (see Section 8).
• Right to restriction: You may request that we restrict Processing of your Personal Data in certain circumstances — for example, while the accuracy of the data is being contested.
• Right to data portability: You may request a structured, machine-readable copy of the Personal Data you have provided to us, where Processing is based on consent or contractual necessity.
• Right to object: You may object to Processing based on legitimate interests or for direct marketing purposes. Where you object to marketing, we will cease Processing for that purpose immediately.
• Right to withdraw consent: Where Processing is based on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of Processing carried out before withdrawal.

To exercise any of these rights, please contact our Data Protection team at [email protected] with the subject line "Data Subject Request". We will respond to all verified requests within 30 calendar days. We may ask you to verify your identity before processing a request to prevent unauthorized access to your data.

13. Third-Party Links and Embedded Content

The naga89 Platform may contain references to third-party sports data providers, game studio content (such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft), and payment service interfaces. Each of these third parties operates under its own privacy policy. naga89 is not responsible for the data practices of any third party whose services are accessed through or integrated with the Platform. We encourage you to review the privacy policies of any third-party service you interact with.

14. Changes to This Privacy Policy

naga89 reserves the right to update or revise this Privacy Policy at any time. When we make material changes, we will post the revised Policy on this page with an updated "Last Updated" date, and — where the changes are significant — we will notify you directly by email or via a prominent notice on the Platform.

Your continued use of naga89 after a revised Policy has been posted constitutes your acceptance of the updated terms. If you do not agree to the revised Policy, you must cease using the Platform and may request Account closure in accordance with our Terms and Conditions.

We recommend reviewing this Policy periodically to stay informed of how we protect your data. Archived versions of previous Policy versions are available upon request.

15. Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or our data practices, please contact our Data Protection team:

• Email: [email protected]
• Subject Line: "Privacy Policy Inquiry" or "Data Subject Request"
• Live Chat: Available 24/7 on the naga89 Platform
• Response Time: Within 24 hours for general inquiries; within 30 calendar days for formal data subject requests

We are committed to resolving all privacy-related concerns fairly and promptly. If you are not satisfied with our response, you may have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.