cumi46 Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal data collected by cumi46 through our website located at https://cumi46.cam, our mobile-optimized platform, and all related services (collectively, the "Platform"). This policy applies to all users who access or use our services, including registered account holders, visitors browsing our website, and individuals who contact our customer support team.

cumi46 operates as an online betting platform serving the Indonesian market. We are committed to complying with applicable data protection laws and regulations, including Indonesian privacy legislation and international best practices for data security and user privacy. As the data controller, we determine the purposes and means of processing your personal information.

This Privacy Policy should be read in conjunction with our Terms and Conditions, which govern your use of cumi46 services. By registering an account or using our platform, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and disclosure of your personal information as described herein.

2. Information We Collect

2.1 Information You Provide Directly

When you register for a cumi46 account, we collect personal information that you provide to us directly, including:

• Registration Information: Full legal name, date of birth, gender, email address, phone number, residential address, and username/password for your account.
• Identity Verification Documents: Copies of your Indonesian National Identity Card (KTP), selfie photographs for identity verification, proof of address documents such as utility bills or bank statements, and any other documents required for KYC (Know Your Customer) compliance.
• Financial Information: Bank account details including bank name, account number, and account holder name for deposits and withdrawals. E-wallet information for OVO, DANA, GoPay, ShopeePay, and LinkAja transactions. Transaction history including deposits, withdrawals, and betting activity.
• Communication Data: Any information you provide when contacting our customer support team via live chat, email, or other communication channels, including the content of your messages, inquiries, and complaints.
• Voluntary Information: Any additional information you choose to provide, such as profile photos, preferences, or feedback through surveys and promotional activities.

2.2 Information Collected Automatically

When you access and use the cumi46 platform, we automatically collect certain technical information, including:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers, and mobile network information.
• Usage Data: Pages visited, time spent on pages, click patterns, navigation paths, games played, bets placed, login times and frequency, and other behavioral data indicating how you interact with our platform.
• Location Data: IP address, country, region, and city derived from your IP address (we do not collect precise GPS location data unless you explicitly grant permission).
• Cookies and Tracking Technologies: Information collected through cookies, web beacons, pixel tags, and similar tracking technologies. See Section 8 for detailed information about our cookie usage.

2.3 Information from Third Parties

We may receive information about you from third-party sources, including:

• Payment Providers: Transaction confirmations and payment status information from Indonesian banks (BCA, BRI, BNI, Mandiri, etc.) and e-wallet services (OVO, DANA, GoPay, ShopeePay, LinkAja).
• Identity Verification Services: Information from third-party KYC verification providers who assist us in verifying your identity and age to comply with legal requirements.
• Fraud Prevention Services: Information from fraud detection and prevention service providers to help us identify suspicious activity and protect against fraudulent transactions.
• Game Providers: Gaming activity data from our game suppliers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, and others regarding your gameplay and results.

3. How We Use Your Information

cumi46 uses your personal information for the following purposes:

3.1 Account Management and Service Delivery

• Creating and maintaining your cumi46 account
• Processing your deposits and withdrawals
• Providing access to betting markets, casino games, and other platform features
• Recording your bets, tracking gaming activity, and calculating winnings
• Settling bets and crediting winnings to your account
• Managing your account preferences and settings

3.2 Legal and Regulatory Compliance

• Verifying your identity and age to ensure you are at least 21 years old
• Complying with KYC and anti-money laundering (AML) regulations
• Preventing fraud, underage gambling, and other illegal activities
• Cooperating with law enforcement and regulatory authorities when legally required
• Maintaining records for audit and compliance purposes

3.3 Customer Support and Communication

• Responding to your inquiries, questions, and support requests
• Sending you important account notifications and service updates
• Notifying you about changes to our Terms and Conditions or Privacy Policy
• Resolving disputes and handling complaints

3.4 Marketing and Promotions

• Sending you promotional offers, bonuses, and special deals (only with your consent)
• Informing you about new games, features, and services
• Administering contests, tournaments, and loyalty programs
• Personalizing marketing communications based on your preferences and activity

3.5 Platform Improvement and Analytics

• Analyzing usage patterns to improve platform functionality and user experience
• Conducting research and analytics on betting behavior and game preferences
• Testing new features and optimizing platform performance
• Identifying and fixing technical issues and bugs

3.6 Security and Fraud Prevention

• Detecting and preventing fraudulent transactions and suspicious activity
• Monitoring for collusion, bonus abuse, and violation of our Terms and Conditions
• Protecting the integrity of our games and betting markets
• Safeguarding our platform against security threats and unauthorized access

4. Legal Basis for Processing

We process your personal information on the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you, including providing betting services, processing transactions, and managing your account.
• Legal Obligation: Processing is required to comply with legal obligations including age verification, KYC requirements, anti-money laundering regulations, and other applicable laws.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, platform security, customer support, and service improvement, provided these interests are not overridden by your data protection rights.
• Consent: For marketing communications and certain optional data collection, we rely on your explicit consent, which you may withdraw at any time.

5. Information Sharing and Disclosure

cumi46 does not sell, rent, or trade your personal information to third parties for their marketing purposes. We may share your information with the following categories of recipients:

5.1 Service Providers

We share data with trusted third-party service providers who assist us in operating our platform and delivering our services, including:

• Payment processors (Indonesian banks and e-wallet providers) for transaction processing
• Identity verification services for KYC compliance
• Game suppliers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, etc.) for game provision
• Cloud hosting and data storage providers
• Customer support software providers
• Marketing and analytics service providers
• Fraud detection and security service providers

All service providers are contractually obligated to use your information only for the specific services they provide to cumi46 and to maintain appropriate security measures.

5.2 Legal and Regulatory Authorities

We may disclose your information to law enforcement, regulatory authorities, courts, or other government agencies when required by law or when we believe disclosure is necessary to:

• Comply with legal processes, court orders, or government requests
• Enforce our Terms and Conditions and other policies
• Protect the rights, property, or safety of cumi46, our users, or the public
• Investigate suspected fraud, illegal activity, or violations of our rules

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the successor entity or acquiring party, subject to the same privacy protections described in this policy.

5.4 With Your Consent

We may share your information with other third parties when you explicitly consent to such sharing, such as when you participate in co-branded promotions or authorize specific data sharing.

6. Data Security

cumi46 takes the security of your personal information seriously and implements appropriate technical and organizational measures to protect your data against unauthorized access, alteration, disclosure, or destruction. Our security measures include:

• Encryption: All data transmission between your device and our servers is protected by industry-standard 256-bit SSL (Secure Socket Layer) encryption. Sensitive data stored on our servers is also encrypted at rest.
• Access Controls: We implement strict access controls ensuring that only authorized personnel can access personal information on a need-to-know basis. All employees with access to personal data are bound by confidentiality obligations.
• Secure Infrastructure: Our platform is hosted on secure servers with firewalls, intrusion detection systems, and regular security audits to identify and address vulnerabilities.
• Regular Security Assessments: We conduct periodic security reviews, penetration testing, and vulnerability assessments to maintain the highest security standards.
• Secure Payment Processing: All payment transactions are processed through secure payment gateways that comply with PCI DSS (Payment Card Industry Data Security Standard) requirements.

While we strive to protect your personal information, no method of electronic transmission or storage is 100% secure. You also play a role in protecting your data by maintaining the confidentiality of your account password, using a secure internet connection, and logging out after each session.

7. Data Retention

cumi46 retains your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Our retention periods are based on the following criteria:

• Active Accounts: While your account remains active, we retain all account information and transaction history to provide ongoing services.
• Closed Accounts: After account closure, we retain certain information for a period of 5 years to comply with legal obligations including anti-money laundering regulations, tax requirements, and to handle any disputes or claims that may arise.
• Marketing Data: If you consent to receive marketing communications, we retain your contact information until you withdraw consent or we determine the data is no longer needed for marketing purposes.
• Technical Data: Log files, IP addresses, and technical data are typically retained for 12 months for security and analytical purposes, after which they are anonymized or deleted.

After the retention period expires, personal information is securely deleted or anonymized so that it can no longer be associated with you.

8. Cookies and Tracking Technologies

cumi46 uses cookies and similar tracking technologies to enhance your experience on our 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.

8.1 Types of Cookies We Use

8.2 Managing Cookies

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies or alert you when cookies are being sent. Please note that disabling certain cookies may affect platform functionality and your user experience. Essential cookies cannot be disabled as they are necessary for the platform to function properly.

9. Your Privacy Rights

As a cumi46 user, you have the following rights regarding your personal information:

• Right to Access: You have the right to request a copy of the personal information we hold about you. We will provide this information in a structured, commonly used format.
• Right to Rectification: If any of your personal information is inaccurate or incomplete, you have the right to request correction or completion. You can update most information directly through your account settings.
• Right to Erasure: You may request deletion of your personal information, subject to our legal obligations to retain certain data for compliance purposes (e.g., financial records for 5 years).
• Right to Restrict Processing: You can request that we limit how we use your personal information in certain circumstances.
• Right to Data Portability: You have the right to receive your personal data in a portable format and transmit it to another service provider where technically feasible.
• Right to Object: You can object to processing of your personal information for marketing purposes or based on legitimate interests. We will respect your objection unless we have compelling legitimate grounds to continue processing.
• Right to Withdraw Consent: Where we rely on your consent to process personal information (e.g., marketing communications), you may withdraw that consent at any time.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] or through our customer support channels. We will respond to your request within 30 days.

10. Children's Privacy

cumi46 services are strictly intended for adults aged 21 and over. We do not knowingly collect personal information from individuals under 21 years of age. If we discover that we have inadvertently collected information from someone under 21, we will immediately delete that information and close any associated account. If you believe we may have collected information from an underage individual, please contact us immediately at [email protected].

11. International Data Transfers

Your personal information may be transferred to and processed in countries outside of Indonesia where our service providers and partners are located. These countries may have different data protection laws than Indonesia. When we transfer your data internationally, we ensure appropriate safeguards are in place to protect your information, such as standard contractual clauses, adequacy decisions, or other legally approved transfer mechanisms.

12. Third-Party Links

The cumi46 platform may contain links to third-party websites or services that are not operated by us. This Privacy Policy does not apply to third-party sites. We are not responsible for the privacy practices or content of third parties. We encourage you to review the privacy policies of any third-party sites you visit.

13. Changes to This Privacy Policy

cumi46 reserves the right to modify or update this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or other operational needs. When we make material changes, we will notify you by updating the "Last Updated" date at the top of this policy and may also send you an email notification or display a prominent notice on our platform.

Your continued use of cumi46 services following any changes to this Privacy Policy constitutes your acceptance of the revised policy. We encourage you to review this policy periodically to stay informed about how we protect your information.

14. Contact Information

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

• Email: [email protected] (Data Protection inquiries) or [email protected] (General inquiries)
• Live Chat: Available 24/7 on the cumi46 platform
• Support Hours: 24 hours a day, 7 days a week
• Languages: Indonesian and English

We take all privacy concerns seriously and will investigate and respond to all legitimate requests within 30 days. If you are not satisfied with our response, you have the right to lodge a complaint with the relevant data protection authority in Indonesia.