Privacy Policy

1 Definitions

Throughout this Privacy Policy, the following terms carry the meanings defined below:

• "ink89", "We", "Us", "Our" — the company operating the online betting and gaming platform at ink89.cam and all associated subdomains.
• "You", "Player", "User" — any individual who accesses, browses, registers on, or uses any service offered by ink89.
• "Personal Data" — any information that can directly or indirectly identify a natural person, including names, identity card numbers, email addresses, IP addresses, device identifiers, and financial account details.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, and deletion.
• "KYC" — Know Your Customer: the identity and age-verification process mandatory for withdrawal-enabled accounts.
• "Controller" — the entity that determines the purposes and means of processing Personal Data. For this policy, ink89 is the data controller.
• "Processor" — a third party that processes Personal Data on behalf of ink89 under a binding data-processing agreement.
• "Cookies" — small text files stored on your device by your browser at the request of ink89's servers, used to maintain session state, preferences, and analytics.

2 Scope & Application

This Privacy Policy applies to all Personal Data collected and processed by ink89 in connection with:

• Your registration and ongoing use of an ink89 Account.
• Your use of any betting, gaming, togel (Indonesia's traditional numbers lottery), or live-casino product offered through the Platform.
• Your communications with ink89's customer support team via live chat, email, or any other channel.
• Your visits to ink89.cam and all associated subdomains, whether or not you hold a registered account.
• Any promotional, loyalty, or VIP program operated by ink89.

This policy does not cover third-party websites, apps, or services that may be linked to or from the Platform. ink89 is not responsible for the privacy practices of those third parties, and we encourage you to read their privacy policies independently.

3 Data We Collect

ink89 collects the following categories of Personal Data:

3.1 Identity Data

• Full legal name as it appears on your government-issued identity document.
• Date of birth (used to verify the mandatory 21+ age requirement).
• Indonesian National Identity Card number (KTP — Kartu Tanda Penduduk) or equivalent government-issued ID for non-Indonesian residents.
• Photograph as submitted during KYC verification.

3.2 Contact Data

• Email address.
• Mobile phone number.
• Residential address (province, city, postal code).

3.3 Financial Data

• Bank account details (bank name, account number, account holder name) for withdrawal processing — e.g., BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, BSI.
• E-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja) used for deposits and withdrawals.
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment methods.

3.4 Technical & Usage Data

• IP address and approximate geographic location derived from it.
• Device type, operating system, browser type and version.
• Pages visited, features used, session duration, and click-stream data.
• Login timestamps, session tokens, and two-factor authentication records.

3.5 Gaming & Betting Data

• Betting history, game selections, wager amounts, and outcomes.
• Bonus and promotional activity, including wagering requirement progress.
• Responsible gaming tool settings — deposit limits, session limits, self-exclusion status.
• Customer support correspondence and complaint records.

3.6 Sensitive Data

ink89 does not intentionally collect sensitive categories of personal data (such as racial or ethnic origin, political opinions, religious beliefs, or health data) unless specifically required by law or provided voluntarily by you in the context of a responsible gaming self-assessment. Where such data is provided, it is treated with the highest level of protection and used solely for the stated purpose.

4 How We Collect Data

ink89 collects Personal Data through the following means:

• Direct submission — information you provide when registering, completing KYC, making a deposit or withdrawal request, contacting support, or participating in a promotion.
• Automated technical collection — data gathered automatically when you access the Platform, including cookies, server logs, and device fingerprinting used for fraud prevention.
• Third-party verification partners — identity and age-verification data returned by our KYC service providers after you submit your documents.
• Payment processors — transaction confirmation data returned by banks and e-wallet providers (BCA, BRI, OVO, DANA, GoPay, etc.) when you make a deposit or withdrawal.
• Fraud and risk-screening providers — flags, scores, and indicators generated by our third-party anti-fraud partners based on device, behavioural, and network signals.

5 Legal Basis for Processing

ink89 processes your Personal Data under one or more of the following legal bases depending on the nature of the processing activity:

6 How We Use Your Data

ink89 uses the Personal Data we collect for the following purposes:

6.1 Account Operations

To create and maintain your Account, authenticate your identity at login, process your bets and gaming transactions, and communicate critical account-related information such as security alerts, transaction confirmations, and policy updates.

6.2 Payments & Financial Processing

To process deposits and withdrawals via your chosen Indonesian payment method (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, BSI, OVO, DANA, GoPay, ShopeePay, or LinkAja), verify the ownership of payment instruments, and maintain accurate financial records in IDR.

6.3 Compliance & Legal Obligations

To fulfil our obligations under applicable anti-money-laundering (AML) and counter-terrorism financing (CTF) regulations, including filing mandatory reports with relevant authorities where required by law. KYC data is retained in line with prescribed record-keeping periods regardless of account status.

6.4 Fraud Prevention & Platform Security

To detect, investigate, and prevent fraudulent activity, bonus abuse, collusion, multi-accounting, and other forms of prohibited conduct. Technical data including IP addresses, device identifiers, and login patterns are used continuously by our automated risk-management systems.

6.5 Responsible Gaming

To monitor betting patterns and account behaviour for indicators of problem gambling, enforce deposit limits, session limits, and self-exclusion orders placed by you or flagged by our responsible gaming team, and to send welfare-check communications where appropriate.

6.6 Customer Support

To respond to your queries, complaints, and requests; to maintain a record of communications for quality assurance and dispute resolution; and to train our support agents to provide better service.

6.7 Marketing Communications (Consent-Based)

If you have opted in to marketing communications, ink89 may use your email address or mobile number to send you information about promotions, new games, seasonal offers (such as Idul Fitri or Ramadhan specials), and VIP program updates. You may withdraw your consent at any time by contacting our support team or using the unsubscribe link in any marketing email. Withdrawal of marketing consent does not affect the lawfulness of prior processing.

6.8 Platform Improvement

To analyse aggregated and anonymised usage data in order to improve the Platform's features, performance, user experience, and game selection. Anonymised analytics data cannot be used to identify individual players.

7 Sharing & Disclosure

ink89 does not sell your Personal Data. We share it only in the following limited circumstances:

7.1 Service Providers (Processors)

We engage carefully vetted third-party service providers who process data on our behalf under binding data-processing agreements. These include:

• Payment processors — Indonesian banks and e-wallet operators required to execute your transactions.
• KYC and identity-verification providers — specialist companies that verify the authenticity of identity documents submitted during account registration.
• Fraud-prevention and device-fingerprinting providers — technology partners whose systems help identify suspicious activity across the Platform.
• Cloud infrastructure and hosting providers — companies that provide the secure server environments on which the Platform operates.
• Customer support platform providers — software vendors whose tools power our live chat and ticketing systems.

7.2 Regulatory and Law-Enforcement Authorities

ink89 may disclose Personal Data to regulatory bodies, law-enforcement agencies, or other governmental authorities where required to do so by applicable law, court order, or lawful request. We will endeavour to notify you of such a disclosure where we are legally permitted to do so.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of ink89's business, your Personal Data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any resulting changes to this Privacy Policy before the transfer takes effect.

7.4 With Your Explicit Consent

We may share your data with third parties not described above if you have given your explicit, informed consent to that specific sharing. You may withdraw such consent at any time by contacting [email protected].

8 Cookies & Tracking Technologies

ink89 uses cookies and similar tracking technologies to operate the Platform correctly, maintain your session, and gather analytics. Below is a summary of the cookie categories in use:

8.1 Cookie Categories

8.2 Managing Cookies

You can manage or delete functional and analytics cookies through your browser settings at any time. Note that disabling strictly necessary or security cookies will impair or fully prevent your ability to use the Platform. Instructions for managing cookies are available in the help documentation for all major browsers.

8.3 No Third-Party Advertising Cookies

ink89 does not place third-party advertising or re-targeting cookies on your device. We do not participate in cross-site behavioural advertising networks.

9 Data Security

ink89 implements a layered security architecture to protect your Personal Data against unauthorised access, disclosure, alteration, and destruction. Our key security measures include:

• 256-bit SSL/TLS encryption on all data in transit between your device and our servers.
• AES-256 encryption for sensitive data stored at rest, including identity documents and financial account details.
• Role-based access controls ensuring that only authorised ink89 personnel can access Personal Data, and only to the extent required for their specific job function.
• Two-factor authentication (2FA) available to all players and mandatory for all ink89 staff with access to player data systems.
• Intrusion detection and prevention systems (IDS/IPS) monitoring network traffic for anomalous patterns in real time.
• Regular penetration testing conducted by independent security firms to identify and remediate vulnerabilities.
• Incident response procedures — in the event of a data breach affecting your Personal Data, ink89 will notify affected players within 72 hours of becoming aware of the incident, where legally required to do so.

Despite these measures, no internet-based system is entirely immune to security risks. You are strongly encouraged to use a strong, unique password for your ink89 Account, enable 2FA, and contact our support team immediately if you suspect unauthorised access.

10 Data Retention

ink89 retains Personal Data for the following periods, after which it is securely deleted or anonymised:

Where retention beyond these periods is required by a specific legal obligation, court order, or ongoing investigation, ink89 will retain the relevant data until that obligation is discharged and then delete it promptly.

11 Your Rights

Subject to applicable law and certain conditions, you have the following rights in relation to your Personal Data held by ink89:

11.1 Right of Access

You may request a copy of the Personal Data ink89 holds about you. We will provide a response within 30 days of receiving a valid, verified request.

11.2 Right to Rectification

If any Personal Data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. For account-level data (name, address, contact details), you may update most information directly in your Account settings. For KYC-verified fields, corrections require re-submission of supporting documentation.

11.3 Right to Erasure

You may request the deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and no other legal basis for processing applies. This right is subject to overriding legal retention obligations — for example, AML record-keeping requirements will take precedence over an erasure request for KYC and transaction data within the mandatory retention period.

11.4 Right to Restriction of Processing

You may request that ink89 restrict the processing of your Personal Data in certain circumstances — for example, while the accuracy of data is being contested, or where you have objected to processing pending verification of legitimate grounds.

11.5 Right to Data Portability

Where processing is carried out by automated means on the basis of your consent or a contract, you have the right to receive a copy of your Personal Data in a structured, commonly used, machine-readable format, and to request that it be transmitted to another controller where technically feasible.

11.6 Right to Object

You may object at any time to the processing of your Personal Data for direct marketing purposes. You may also object to processing carried out on the basis of legitimate interest, where your particular circumstances warrant it. ink89 will cease processing for marketing purposes immediately upon receipt of your objection; objections to other processing will be assessed case by case.

11.7 Exercising Your Rights

To exercise any of the rights described above, please submit a written request to [email protected] from the email address registered to your Account. We may need to verify your identity before processing the request. We will respond within 30 days; complex or high-volume requests may be extended by a further 60 days with prior notice.

12 Children & Minors

ink89's services are strictly for individuals aged 21 years and older. We do not knowingly collect, store, or process Personal Data from anyone under the age of 21. Registration attempts by individuals under 21 are blocked at the point of KYC verification.

If you are a parent or guardian and believe that a person under 21 in your care has provided Personal Data to ink89 without your consent, please contact us immediately at [email protected]. We will investigate promptly, close any under-age account identified, delete the associated Personal Data, and refund any funds deposited by a verified minor.

We strongly encourage parents and guardians to make use of parental control software to prevent underage access to online gambling platforms. A list of recommended parental control tools is available on our Responsible Gaming page.

13 International Data Transfers

ink89 operates globally and may store or process your Personal Data on servers located outside of Indonesia. Where your data is transferred to countries that do not have data-protection laws equivalent to internationally recognised standards, ink89 implements one or more of the following safeguards:

• Standard contractual clauses approved by relevant data-protection authorities, incorporated into agreements with the relevant data recipients.
• Binding corporate rules, where applicable to transfers within the ink89 corporate group.
• Data-processing agreements requiring the recipient to apply security and privacy standards at least equivalent to those described in this policy.

You may request details of the specific safeguards in place for any particular transfer by contacting [email protected].

14 Policy Updates

ink89 may update this Privacy Policy from time to time to reflect changes in our data-processing practices, legal obligations, or the services we offer. When we make material changes, we will notify you by email to your registered address at least seven calendar days before the revised policy takes effect.

The effective date and last-updated date at the top of this page will always reflect the most current version. We encourage you to review this page periodically. Continued use of the Platform after the effective date of any revision constitutes your acknowledgement of the updated policy.

15 Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or to ink89's handling of your Personal Data, please contact our Data Protection team:

15.1 Complaints

If you are not satisfied with how ink89 has handled your Personal Data or responded to a data-rights request, you have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction. ink89 will cooperate fully with any such authority in the investigation of a complaint.

We ask that you contact us directly in the first instance — our team is committed to resolving privacy concerns promptly and fairly, and most issues can be addressed without the need for formal regulatory intervention.