ink78 Privacy Policy

Introduction

ink78 is an internationally operated online betting and casino platform serving English-preference players across Indonesia. As part of operating the Platform, ink78 necessarily collects and processes certain categories of personal data about its registered players and website visitors. This Privacy Policy sets out, in plain terms, exactly what that data is, why it is collected, how long it is retained, and the rights that you — as the person whose data it is — hold at all times.

ink78 is committed to data minimisation: we collect only what is genuinely required to provide you with a secure, functional, and personalised betting and gaming experience. We do not build advertising profiles, we do not sell data, and we do not share your information with unaffiliated third parties for commercial purposes.

If you are an Indonesian resident, you should be aware that Indonesia's personal data protection framework continues to evolve. ink78 applies internationally recognised data protection principles — lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, and confidentiality — as the baseline standard for all data processing activities on the Platform.

Definitions

Data We Collect

ink78 collects the following categories of personal data, depending on the nature of your interaction with the Platform:

3.1 Registration Data

• Full legal name
• Date of birth
• Email address
• Mobile phone number
• Username and encrypted password
• City and country of residence (Indonesia, by default)

3.2 KYC & Identity Verification Data

• Government-issued national identity card (KTP) number and image
• Selfie photograph (where requested for liveness verification)
• Proof of address documents (where requested)
• Bank account details (account holder name, account number, bank name — e.g., BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI)
• E -wallet account details (OVO, DANA, GoPay, ShopeePay, or LinkAja — where used for deposits or withdrawals)

3.3 Financial Transaction Data

• Deposit amounts, timestamps, and payment method references
• Withdrawal requests, amounts, and processing status
• Transaction history maintained for audit and anti-money-laundering compliance

3.4 Gameplay & Betting Data

• Bet history, wager amounts, game selections, and settlement outcomes across all products (sportsbook, live casino, slots, esports, and togel — Indonesia's traditional numbers lottery)
• Bonus activation, wagering progress, and promotion participation records
• Session duration, login timestamps, and in-session activity logs

3.5 Technical & Device Data

• IP address and approximate geographic location derived from IP
• Device type, operating system, browser type and version
• Referral source (where applicable)
• Cookie identifiers and session tokens (see Section 10)

3.6 Communications Data

• Records of support conversations conducted via live chat or email
• Feedback, complaints, and dispute correspondence
• Promotional preference settings and opt-in/opt-out records for marketing communications

How We Collect Data

ink78 collects personal data through the following channels:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, place a bet, contact support, or participate in a promotion.
• Automatically: When you browse or interact with the Platform, technical data such as your IP address, device identifiers, and session behaviour are captured automatically via server logs and cookies.
• From third-party processors: Payment providers (e.g., BCA, BRI, Mandiri, OVO, GoPay) may return transaction confirmation data to ink78. KYC verification partners may return identity-match results. These processors operate under contractual data-processing agreements with ink78 and are permitted to use your data only for the specific purpose of completing the service in question.

Purpose of Processing

ink78 processes your personal data only for the following defined purposes. We do not use your data for any purpose incompatible with those listed here without first obtaining your explicit consent.

Legal Basis for Processing

ink78 processes personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual necessity: Processing required to enter into or perform the contract between ink78 and you as a registered Player — including account creation, payment processing, and bet settlement.
• Legal obligation: Processing required to comply with applicable legal and regulatory requirements, including KYC/AML obligations and the retention of financial records.
• Legitimate interests: Processing necessary for ink78's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and product improvement — where these interests are not overridden by your fundamental rights.
• Consent: Where ink78 relies on consent (for example, for sending marketing communications or promotional offers), you may withdraw that consent at any time by updating your communication preferences in your account settings or by contacting support.

Data Sharing

ink78 does not sell, rent, or trade your personal data with any third party for commercial purposes. Your data may be shared only in the following limited circumstances:

• Payment processors: Transactional data is shared with your chosen payment provider (bank or e-wallet) to complete deposits and withdrawals. These providers receive only the minimum data necessary for the transaction.
• KYC verification partners: Identity document data is transmitted to our contracted KYC service provider for the sole purpose of confirming your identity and age. The KYC partner is contractually prohibited from using your data for any other purpose.
• Game studio providers: Where required for fair-play auditing or dispute resolution, limited gameplay data may be shared with the relevant licensed studio partner (e.g., Pragmatic Play, Evolution Gaming, Spribe, Microgaming, Pocket Games Soft). No financial or identity data is shared with studios.
• Law enforcement and regulatory bodies: ink78 will disclose personal data to competent authorities where required by law, court order, or regulatory direction. In such cases, ink78 will share only the data specifically requested and will, where legally permissible, notify the affected Player.
• Business successors: In the event of a merger, acquisition, or sale of substantially all of ink78's assets, personal data held by ink78 may be transferred to the successor entity, subject to that entity assuming the obligations of this Privacy Policy.

Data Retention

ink78 retains personal data for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable legal and compliance obligations. The following general retention periods apply:

• Active account data: Retained for the full duration of your account's active status plus a minimum of five (5) years following account closure, to meet financial record-keeping and AML obligations.
• KYC documents: Retained for a minimum of five (5) years from the date of verification or from the date of account closure, whichever is later.
• Transaction records: Retained for a minimum of five (5) years for AML audit and regulatory compliance purposes.
• Support communications: Retained for three (3) years from the date of the last communication in a given thread, unless the communication is part of an active or reasonably foreseeable dispute.
• Technical and session logs: Retained for up to twelve (12) months in identifiable form, after which they are anonymised or deleted.
• Marketing preferences: Retained until you withdraw consent or close your account, whichever occurs first.

Once a retention period expires and no other legal basis for continued storage exists, ink78 will securely delete or irreversibly anonymise the relevant data.

Data Security

ink78 implements and maintains a layered set of technical and organisational security measures designed to protect personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport-layer encryption: All data transmitted between your device and ink78's servers is protected by TLS 1.2 or higher (HTTPS/SSL). Connections using outdated protocols are rejected.
• At-rest encryption: Sensitive data — including KYC documents, financial records, and passwords — is encrypted at rest using AES-256.
• Password hashing: Account passwords are stored exclusively as salted cryptographic hashes. ink78 staff cannot retrieve plain-text passwords under any circumstances.
• Access controls: Personal data is accessible only to ink78 personnel who require it to perform their specific job function. Access is governed by a role-based permissions system and is logged for audit purposes.
• Network security: The Platform infrastructure is protected by firewall rules, intrusion-detection systems, and DDoS mitigation mechanisms.
• Penetration testing: ink78 conducts periodic security assessments, including third-party penetration tests, to identify and remediate vulnerabilities.

Cookies & Tracking Technologies

ink78 uses cookies and similar tracking technologies to ensure the Platform functions correctly, to maintain your session state, and to gather aggregated analytics that help us improve performance and user experience. The following categories of cookies may be set when you visit the Platform:

• Strictly necessary cookies: Required for core Platform functionality, including session authentication, security tokens, and load-balancing. These cookies cannot be disabled without impairing basic features of the Platform.
• Functional cookies: Used to remember your preferences — such as your preferred language setting or cached balance display — to improve your experience between sessions.
• Analytics cookies: Aggregate, pseudonymised data about how players navigate the Platform, which pages are visited most frequently, and where errors are encountered. This data is used internally to guide product improvements. No individually identifiable data is transmitted to analytics processors.
• Marketing cookies: Set only where you have provided explicit consent. Used to recognise returning visitors and to measure the effectiveness of promotional campaigns. You may withdraw consent for marketing cookies at any time.

You can control cookie settings through your browser's built-in controls. Note that disabling strictly necessary cookies will impair Platform functionality, including the ability to log in or maintain a session. For detailed instructions on managing cookies in your specific browser, consult your browser's help documentation.

Your Rights

As a Player whose personal data is processed by ink78, you hold the following rights. To exercise any of these rights, contact ink78 support at the details provided in Section 16. ink78 will respond to valid rights requests within 30 calendar days.

Minors

ink78 strictly prohibits access by individuals under the age of 21. The Platform does not knowingly collect personal data from anyone under 21 years of age. Age is verified as a mandatory step during the KYC process prior to any withdrawal being processed.

If ink78 becomes aware that personal data has been collected from an individual who is under 21, the account will be suspended immediately, the data will be securely deleted, and any balance held will be handled in accordance with the account suspension provisions in the ink78 Terms & Conditions. If you are a parent or guardian and believe your child has registered an account on the Platform, please contact support immediately at [email protected].

Third-Party Services

The ink78 Platform integrates with third-party services — including licensed game studio providers (such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Pocket Games Soft), payment processors, and KYC verification vendors — to deliver its full range of features. Each of these third parties operates under its own privacy policy and data-handling practices.

ink78 conducts due diligence on all third-party processors before engagement and requires contractual data-processing agreements that bind processors to handle your data only for the specific purpose for which it was shared and to maintain appropriate security standards. However, once data passes to a third-party service beyond ink78's direct control (for example, your bank's processing network), ink78 cannot accept liability for how that third party handles your data.

This Privacy Policy does not extend to any third-party website, service, or platform that you may access via links on the Platform. ink78 strongly encourages you to review the privacy policies of any third-party service you engage with independently.

International Data Transfers

ink78 operates as an internationally hosted platform. Personal data collected from players in Indonesia may be processed on servers located outside Indonesia. Where such transfers occur, ink78 takes steps to ensure that adequate protections are in place for your data, including through the use of contractual clauses that require receiving parties to provide a level of protection equivalent to that applied within the Platform itself.

By registering an account and using the ink78 Platform, you acknowledge and consent to the transfer of your personal data to and from servers located in jurisdictions outside Indonesia for the purposes described in this Privacy Policy.

Policy Amendments

ink78 reserves the right to update this Privacy Policy at any time. Where a material change is made — for example, a change to the categories of data collected, a new data-sharing arrangement, or a change to your rights — ink78 will notify registered Players via their registered email address at least 7 days before the updated policy takes effect.

The current version number and effective date are always displayed at the top of this page. Minor, non-material changes (such as typographic corrections or clarifications that do not alter your rights) may be made without advance notice. Continued use of the Platform following the effective date of any revised Privacy Policy constitutes your acceptance of the changes.

Contact

If you have questions about this Privacy Policy, wish to exercise any of your data rights, or want to raise a data-related concern, please contact the ink78 data team through the following channel:

• Email: [email protected] — please include "Privacy Request" in the subject line so your message is routed directly to the data team.
• Live Chat: Available 24/7 after logging in to your ink78 account. Native Indonesian-speaking agents are on duty at all times (WIB).
• Response time: Rights requests and privacy queries are addressed within 30 calendar days of receipt. Complex requests may require an extension; if so, you will be notified within the initial 30-day window.