Privacy Policy

The following terms carry the meanings set out below throughout this Privacy Policy:

• "ink79" / "we" / "us" / "our" refers to the ink79 online gaming and sports betting platform operating at https://ink79.cam.
• "User" / "you" / "your" refers to any individual who accesses, browses, registers on, or otherwise interacts with the ink79 platform.
• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, date of birth, email address, payment details, device identifiers, and IP addresses.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, or deletion.
• "Data Controller" means the entity that determines the purposes and means of Processing Personal Data — in this context, ink79.
• "Data Processor" means any third party that processes Personal Data on behalf of ink79 under a written data processing agreement.
• "KYC" means Know Your Customer — the identity verification process conducted prior to processing withdrawals.
• "Cookies" means small text files stored on your device by the ink79 platform to facilitate session management, analytics, and personalization.
• "Third Party" means any entity other than ink79 or the User.

ink79 collects Personal Data across the following categories. The specific data points collected depend on the nature of your interaction with the Platform:

Sensitive Data: ink79 does not deliberately collect sensitive personal data (such as health information, religious beliefs, or biometric data) except where strictly required for responsible gaming assessments or as mandated by applicable law. Where such data is collected, explicit consent is obtained in advance.

ink79 collects Personal Data through the following channels:

• Direct Submission: Data you actively provide during account registration, KYC document upload, deposit and withdrawal requests, and customer support interactions.
• Automated Technologies: Data collected automatically as you use the Platform, including through cookies, server logs, pixel tags, and session recording tools. See Section 9 for full cookie details.
• Third-Party Sources: Data received from payment processors (e.g., BCA, BRI, OVO, DANA), fraud prevention services, identity verification agencies, and analytics providers — to the extent permitted by applicable law and the third party's own privacy policies.
• Device & Network Data: Technical information collected automatically from the device and network you use to access the Platform, including IP address geolocation data which ink79 uses to enforce geographic access restrictions and detect VPN usage.

ink79 processes Personal Data for the following specific purposes:

1. Account Management: Creating and maintaining your account, authenticating logins, and enabling access to the Services.
2. Payment Processing: Facilitating deposits and withdrawals through your chosen payment channel, and maintaining accurate transaction records.
3. Identity Verification (KYC): Verifying your identity and age (21+) in compliance with our licensing obligations and anti-money laundering requirements.
4. Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, and abuse of Platform systems.
5. Regulatory Compliance: Meeting obligations under our operating license, including record-keeping, reporting suspicious transactions, and cooperating with lawful regulatory requests.
6. Customer Support: Responding to your queries, complaints, and support requests through live chat, email, and other support channels.
7. Platform Improvement: Analyzing usage patterns to improve the platform's performance, design, and range of Services.
8. Responsible Gaming: Monitoring for indicators of problem gambling behavior, enforcing self-exclusion requests, and administering deposit limits and cooling-off periods.
9. Marketing Communications: Sending you promotional offers, bonus notifications, and platform updates — but only if you have opted in to receive such communications. You may withdraw consent at any time by contacting [email protected].

ink79 processes your Personal Data on the following legal bases:

• Contractual Necessity: Processing required to fulfill the contract between you and ink79 (the Terms & Conditions), including account management and payment processing.
• Legitimate Interests: Processing necessary for ink79's legitimate business interests, including fraud prevention, security monitoring, and platform analytics — provided these interests are not overridden by your rights and freedoms.
• Legal Obligation: Processing required to comply with licensing conditions, anti-money laundering regulations, and other applicable legal requirements.
• Consent: Processing based on your freely given, specific, informed consent — primarily for marketing communications and optional analytics features. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

ink79 does not sell your Personal Data. We share data only in the following circumstances and only to the minimum extent necessary:

• Payment Processors: Bank partners (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) receive transaction data necessary to process your deposits and withdrawals. These processors are contractually bound to handle your data securely and only for the purpose of payment execution.
• Identity Verification Providers: Third-party KYC and AML screening services that assist in verifying your identity and detecting sanctioned or high-risk individuals. These providers operate under strict data processing agreements with ink79.
• Regulatory Authorities: Where required by applicable law or our operating license, ink79 may disclose Personal Data to regulatory bodies, law enforcement agencies, or courts. ink79 will, where legally permitted, notify you of such disclosure.
• Fraud Prevention Networks: ink79 participates in industry fraud prevention networks and may share data with these networks to identify and block fraudulent activity across multiple platforms.
• Game Software Providers: Third-party game studios (such as Pragmatic Play, Evolution Gaming, and others) may receive anonymized session data required to operate the games. No directly identifiable personal data is shared with game providers.
• Professional Advisors: Lawyers, auditors, and consultants who require access to Personal Data in the course of providing professional services to ink79, subject to confidentiality obligations.

ink79 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. The following general retention periods apply:

Following the expiry of a retention period, Personal Data is securely deleted or anonymized so that it can no longer be associated with an individual User. Anonymized, aggregated data may be retained indefinitely for platform analytics purposes.

ink79 implements a comprehensive set of technical and organizational security measures to protect your Personal Data against unauthorized access, disclosure, alteration, and destruction:

• Encryption in Transit: All data transmitted between your device and ink79 servers is encrypted using 256-bit SSL/TLS protocols. Connections over unencrypted HTTP are automatically redirected to HTTPS.
• Encryption at Rest: Sensitive Personal Data stored in ink79 databases (including financial details and KYC documents) is encrypted using AES-256 encryption.
• Access Controls: Access to Personal Data is strictly role-based. Staff members can only access data categories that are necessary for their specific job function. All data access events are logged and regularly audited.
• Two-Factor Authentication: Internal systems containing Personal Data require two-factor authentication for all staff access, regardless of role level.
• Penetration Testing: ink79 commissions regular third-party penetration tests and vulnerability assessments of its infrastructure and application stack.
• Incident Response: ink79 maintains a documented data breach response procedure. In the event of a confirmed breach that poses a risk to Users, we will notify affected individuals and relevant authorities within the timeframe required by our licensing obligations.

ink79 uses cookies and similar tracking technologies to operate and improve the Platform. The following cookie categories are used:

• Strictly Necessary Cookies: Essential for the Platform to function — including session authentication, security tokens, and load balancing. These cannot be disabled.
• Functional Cookies: Store your preferences (language, display settings, last-visited sections) to personalize your experience across sessions.
• Analytics Cookies: Used to understand how users navigate the Platform — pages visited, time on page, click paths, and error events. This data is aggregated and anonymized wherever possible. We use this information to improve Platform performance and content.
• Responsible Gaming Cookies: Track session duration and betting activity to power the Reality Check and session time reminder features. These are required for responsible gaming compliance and cannot be disabled.

You may manage non-essential cookie preferences through your browser settings. Note that disabling functional or analytics cookies may affect certain Platform features. Strictly necessary and responsible gaming cookies cannot be disabled as they are integral to Platform operation and regulatory compliance.

ink79 does not use third-party advertising cookies or behavioral tracking cookies that build cross-site profiles for commercial targeting.

As a User of the ink79 Platform, you hold the following rights with respect to your Personal Data. To exercise any of these rights, submit a written request to [email protected] with the subject line "Data Rights Request":

1. Right of Access: You may request a copy of all Personal Data ink79 holds about you, along with details of how it is processed.
2. Right to Rectification: You may request correction of any inaccurate or incomplete Personal Data. Account profile information can often be updated directly within the account settings panel.
3. Right to Erasure ("Right to be Forgotten"): You may request deletion of your Personal Data. Note that this right is subject to exceptions — where ink79 is required by law or licensing obligation to retain data, erasure cannot be completed for the relevant data categories until the retention period expires.
4. Right to Restriction of Processing: In certain circumstances, you may request that ink79 restrict the processing of your Personal Data while a dispute or rectification request is resolved.
5. Right to Data Portability: You may request a structured, machine-readable copy of Personal Data you have provided to ink79, to the extent technically feasible.
6. Right to Object: You may object to processing of your Personal Data where ink79 relies on legitimate interests as its legal basis, or where data is used for direct marketing purposes.
7. Right to Withdraw Consent: Where processing is consent-based (e.g., marketing emails), you may withdraw consent at any time without penalty. Withdrawal does not affect the lawfulness of prior processing.

ink79 will respond to all data rights requests within 30 calendar days of receipt. Where a request is complex or numerous, we may extend this period by an additional 30 days, with prior notification to you.

The ink79 Platform is strictly intended for adults aged 21 and over. We do not knowingly collect Personal Data from any individual under the age of 21. If ink79 becomes aware that Personal Data has been collected from a User who is under 21 years of age, that account will be suspended immediately, all data relating to the minor will be deleted as soon as practicable, and any deposits made will be returned to the originating payment method following verification.

If you are a parent or guardian and believe that a minor in your care has registered on ink79, please contact us immediately at [email protected] with the subject line "Minor Account Report". We will investigate and act within 48 hours.

ink79's primary user base is in Indonesia; however, our technical infrastructure, Data Processors, and game software providers operate in multiple jurisdictions globally. As a result, your Personal Data may be transferred to, stored in, and processed in countries outside Indonesia.

When Personal Data is transferred internationally, ink79 implements appropriate safeguards to ensure your data receives a consistent level of protection regardless of where it is processed. These safeguards include:

• Standard contractual clauses requiring Data Processors to apply equivalent data protection standards.
• Data processing agreements that restrict the purposes for which transferred data may be used.
• Technical measures (encryption, access controls) that apply equally regardless of the processing location.

By using the ink79 Platform, you acknowledge and accept that your Personal Data may be processed in jurisdictions outside Indonesia, subject to the safeguards described above.

The ink79 Platform integrates with third-party services including payment processors, game software studios, analytics tools, and customer support platforms. Each of these third-party services operates under its own privacy policy.

ink79 is not responsible for the data practices of third-party services accessed through or referenced by the Platform. We encourage you to review the privacy policies of any third-party service provider whose tools you interact with directly. Where we share data with third-party processors, we do so under contractual data protection obligations, as described in Section 6.

ink79's Platform does not contain embedded third-party advertising networks, social media tracking pixels, or affiliate marketing trackers that collect data for cross-site behavioral profiling purposes.

ink79 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or operational structure. When material changes are made, we will update the "Last Updated" date at the top of this page and, where practicable, notify registered Users by email.

We encourage you to review this Privacy Policy periodically. Your continued use of the Platform following publication of an updated Policy constitutes your acknowledgment of the changes. If you do not agree with the updated terms, you should cease using the Platform and may request account closure as described in the Terms & Conditions.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data, please contact ink79's data protection team using the details below:

• Email: [email protected] — Subject line: "Privacy Policy Inquiry" or "Data Rights Request"
• Response Time: We aim to acknowledge all privacy-related inquiries within 48 hours and resolve them within 30 calendar days.
• Data Rights Requests: For formal requests to access, rectify, restrict, port, or delete your data, use the subject line "Data Rights Request" and include your registered account email address and a description of your request.

If you are not satisfied with ink79's response to a privacy complaint, you have the right to escalate the matter to the data protection authority in the jurisdiction in which ink79 holds its operating license. Contact details for the relevant authority will be provided upon request.