Privacy Policy — 989a

This Privacy Policy applies to all services offered by 989a through its website at https://989a.cam and any associated mobile or software interfaces (collectively referred to as the "Platform"). It governs the collection, storage, processing, and disclosure of personal data relating to individuals who visit, register on, or interact with the Platform.

By accessing the 989a Platform or registering a Member account, you acknowledge that you have read, understood, and consent to the data practices described in this Privacy Policy. If you do not agree with any part of this policy, you should discontinue use of the Platform immediately.

This Privacy Policy should be read in conjunction with our Terms & Conditions, which together constitute the full agreement between 989a and its Members regarding the use of the Platform.

For the purposes of applicable data protection legislation, 989a acts as the data controller in respect of the personal data collected through the Platform. As data controller, 989a determines the purposes for which personal data is processed and the manner in which it is processed.

Where 989a engages third-party service providers (such as KYC verification partners, payment processors, or cloud infrastructure providers) to process personal data on its behalf, those parties act as data processors and are bound by contractual obligations to process data only according to 989a's documented instructions and in compliance with applicable data protection standards.

Any questions, requests, or complaints concerning the processing of your personal data may be directed to the 989a Data Protection team at [email protected].

989a collects only the personal data that is necessary and proportionate to the purposes for which it is processed. The categories of personal data we collect include:

3.1 Identity Data

3.2 Contact Data

• Email address (used for account communication, security alerts, and — with your consent — promotional messages).
• Mobile telephone number registered in Indonesia.

3.3 Financial Data

• Bank account details, including account name, account number, and bank name (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, or Bank Permata).
• Transaction history: deposit amounts, withdrawal requests, wager amounts, and bonus credits in Indonesian Rupiah (IDR).
• Payment method type (e.g., local bank transfer, e-wallet). 989a does not store full credit or debit card numbers.

3.4 Technical Data

• IP address, device type, operating system, and browser version at time of login.
• Session duration, login timestamps, and geolocation data at country/city level.
• Cookies and similar tracking technologies — see Clause 10 for full details.

3.5 Behavioral & Gaming Data

• Game history, including titles played, wager amounts, win/loss records, and session durations across all product categories including sports betting, live dealer tables, slot games, and togel (Indonesia's traditional numbers lottery).
• Betting preferences, favorite markets, and promotional offer engagement history.
• Customer support interaction records, including chat transcripts and email correspondence.

989a collects personal data through the following channels and mechanisms:

• Direct Registration: Information you provide when creating a 989a account, completing KYC verification, updating your profile, or submitting a support request.
• Transaction Processing: Data generated automatically when you deposit or withdraw funds via BCA, BRI, BNI, Mandiri, or other accepted local banks.
• Platform Interaction: Behavioral and technical data collected automatically as you navigate and use the Platform, including pages visited, games launched, and time spent per session.
• Cookies & Tracking Technologies: Data collected via first-party cookies and similar technologies placed on your browser or device when you visit the Platform. See Clause 10 for a full breakdown.
• Third-Party Verification Services: Identity and age verification data returned to 989a by our KYC compliance partners following document checks.
• Fraud Prevention Systems: Data gathered by automated risk-management systems that monitor account activity for patterns consistent with fraudulent or prohibited behavior.

989a processes your personal data for clearly defined purposes only. We do not process personal data in ways that are incompatible with the purposes described below:

989a relies on one or more of the following legal bases when processing your personal data, depending on the specific purpose and category of data involved:

• Contract Performance: Processing necessary to fulfill our obligations to you under the Terms & Conditions — including account administration, payment processing, and game result settlement.
• Legal Obligation: Processing required by applicable law or regulation, including KYC identity verification, AML record-keeping, and regulatory reporting obligations.
• Legitimate Interests: Processing conducted in pursuit of 989a's legitimate business interests — such as fraud prevention, platform security, and service improvement — provided those interests are not overridden by your privacy rights.
• Consent: Processing carried out on the basis of your explicit, freely given consent — principally in the context of marketing communications and the use of non-essential cookies. You may withdraw consent at any time without detriment.

989a does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share personal data only in the following circumstances and strictly to the extent necessary for each purpose:

• KYC & Identity Verification Partners: We share identity documents and biometric data with regulated third-party KYC service providers solely for the purpose of verifying your identity and age. These partners are contractually prohibited from using your data for any other purpose.
• Payment Processors & Banking Partners: Financial data is shared with relevant Indonesian banking institutions (such as BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, and Bank Permata) and e-wallet operators solely to process your deposit and withdrawal transactions.
• Game Studio Providers: Limited technical data (such as an anonymized session token) may be passed to third-party game studios including Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Pocket Games Soft to facilitate gameplay and game result logging.
• Fraud Prevention & Security Services: Anonymized or pseudonymized account behavior data may be shared with industry fraud-prevention networks to identify and block known bad actors.
• Legal & Regulatory Authorities: 989a will disclose personal data to law enforcement agencies, regulatory bodies, or courts of competent jurisdiction when required to do so by a valid legal process, court order, or regulatory demand.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of 989a's assets, Member data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

989a's primary server infrastructure is designed to serve Indonesian Members (WIB, UTC+7) with low-latency performance. However, certain third-party service providers — including KYC verification partners and cloud infrastructure providers — may process or store data on servers located outside Indonesia.

Where personal data is transferred internationally, 989a ensures that appropriate safeguards are in place, including:

• Contractual data processing agreements incorporating standard data protection clauses that bind the recipient to adequate privacy and security standards.
• Transfers only to service providers that operate under internationally recognized security frameworks (such as ISO 27001 certification or equivalent).
• Minimization of the data transferred to only what is strictly necessary for the relevant processing purpose.

By using the 989a Platform, you acknowledge and consent to the transfer of your personal data to the locations described above, subject to the safeguards detailed in this clause.

989a retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our standard retention periods are as follows:

After the applicable retention period has expired, personal data is securely deleted or anonymized so that it can no longer be associated with any identifiable individual.

989a uses cookies and similar technologies to deliver, maintain, and improve Platform services. Cookies are small text files stored on your device when you visit the Platform. They do not contain executable code and cannot be used to access other data on your device.

10.1 Types of Cookies We Use

• Essential Cookies: Strictly necessary for the Platform to function. They enable core features such as session authentication, security token validation, and fraud detection. These cookies cannot be disabled without rendering the Platform inoperable.
• Performance Cookies: Collect anonymized data about how Members interact with the Platform — including page load times, error reports, and navigation paths — to help us identify and resolve technical issues.
• Functional Cookies: Remember your language preferences, display settings, and previously selected payment methods to deliver a more personalized experience on return visits.
• Analytics Cookies: Used to compile aggregate, non-personally-identifiable statistical reports on Platform traffic and usage patterns. These reports inform product development decisions.

10.2 Managing Your Cookie Preferences

You may configure your browser to refuse or delete non-essential cookies at any time. Please note that disabling certain cookies may impair the performance or availability of some Platform features. Essential cookies required for security and authentication cannot be disabled while you are actively using the Platform.

As a data subject, you hold the following rights in relation to your personal data processed by 989a. These rights may be exercised at any time by contacting our support team at [email protected]. We will respond to verified requests within a reasonable timeframe and in accordance with applicable law.

989a implements a comprehensive, layered security framework to protect Member personal data against unauthorized access, disclosure, alteration, and destruction. Our security measures include:

• Encryption in Transit: All data transmitted between your device and the 989a Platform is protected by 256-bit SSL/TLS encryption, ensuring that data cannot be intercepted or read by unauthorized parties during transmission.
• Encryption at Rest: Sensitive data fields — including identity documents, KYC records, and financial account details — are encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Internal access to Member personal data is restricted to authorized 989a personnel who require it to perform specific, documented job functions. Access is governed by role-based permissions and audit-logged.
• Multi-Factor Authentication: Administrative access to systems holding Member data requires multi-factor authentication. Members are also encouraged to use strong, unique passwords for their 989a accounts.
• Intrusion Detection & Monitoring: 989a operates continuous intrusion detection systems and security monitoring protocols. Anomalous access patterns trigger automated alerts for immediate investigation.
• Data Breach Response: In the event of a personal data breach that poses a risk to affected Members, 989a will notify impacted individuals promptly and take all necessary remedial action to contain and mitigate the breach.

The 989a Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that a Member account has been registered by or on behalf of a person under 21 years of age, the following steps will be taken immediately:

• The account will be suspended and then permanently closed.
• All personal data associated with the underage account will be securely deleted to the extent permitted by law.
• Any deposits made by the underage individual will be refunded, subject to identity verification of the refund recipient.
• The matter may be referred to relevant authorities where required by applicable child protection or gaming regulation.

Parents and guardians who believe that a minor in their care has accessed or registered on the 989a Platform should contact us immediately at [email protected] so that we can take prompt remedial action.

The 989a Platform may contain references to, or integrations with, third-party services — including game studio software from providers such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Pocket Games Soft. These third-party services operate independently of 989a and are governed by their own privacy policies.

989a does not control and is not responsible for the data practices of third-party service providers accessed through the Platform. We recommend that you review the privacy policies of any third-party service you interact with, particularly with respect to their use of cookies and behavioral data.

This Privacy Policy applies solely to personal data collected and processed by 989a through the Platform itself. It does not extend to data processed by third-party providers acting as independent data controllers.

989a reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made to this policy, we will notify registered Members via email or in-platform notification prior to the changes taking effect.

• The "Last Updated" date at the top of this document will be revised each time the policy is amended.
• Your continued use of the 989a Platform following the effective date of any amended Privacy Policy constitutes your acknowledgment of and agreement to the revised terms.
• Where an amendment materially affects your rights or the basis on which we process your data, we will seek fresh consent where required by applicable law before proceeding with the updated processing.

We encourage you to review this Privacy Policy periodically to stay informed of how 989a handles your personal information. The most current version of this policy is always available at https://989a.cam/privacy-policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 989a, please reach out to our dedicated Data Protection team. We aim to respond to all verified data-subject requests within a reasonable period and in full compliance with applicable data protection obligations.