Privacy Policy

1Introduction

ular88 is an internationally operated online gaming platform serving players across Indonesia and selected international markets. We recognize that privacy is a fundamental right and that Members of an online gambling platform entrust us with particularly sensitive personal and financial data. This Policy sets out, in clear and accessible terms, exactly how that data is handled — from the moment you visit our website to the point at which your account is permanently closed.

We are committed to processing personal data in accordance with applicable international data protection principles, including purpose limitation, data minimization, accuracy, storage limitation, integrity, confidentiality, and accountability. Where Indonesian personal data protection regulations (including Law No. 27 of 2022 on Personal Data Protection, "PDP Law") apply to our processing activities, we comply with those requirements.

2Data Controller

ular88 acts as the data controller for personal data collected through the Platform. For questions about data processing, subject access requests, or this Privacy Policy, the primary point of contact is our Data Protection team, reachable at:

• Email: [email protected]
• Live Chat: Available 24/7 directly on the Platform
• Response Time: Data-related inquiries are acknowledged within 48 hours and resolved within 30 days

3Data We Collect

ular88 collects personal data in the following categories. We collect only the minimum data necessary for the stated purpose (data minimization principle).

Category	Examples	Purpose
Identity Data	Full legal name, date of birth, gender, nationality, Indonesian KTP number or passport number	Account registration, KYC verification, age verification (21+)
Contact Data	Email address, Indonesian mobile phone number, residential address (city, province)	Account communications, support, fraud alerts
Financial Data	Bank account name and number (BCA, BRI, BNI, Mandiri, CIMB Niaga), e-wallet account details (OVO, DANA, GoPay, ShopeePay, LinkAja), transaction history, deposit and withdrawal records	Payment processing, AML compliance, withdrawal verification
Technical Data	IP address, device type and OS, browser type and version, session timestamps, geolocation (city/region level)	Security monitoring, fraud detection, platform optimization
Usage Data	Pages visited, games played, bets placed, session duration, feature interactions	Platform improvement, responsible gaming monitoring, personalization
Communications Data	Live chat transcripts, support ticket content, email correspondence	Dispute resolution, service improvement, regulatory compliance
KYC Document Data	Scanned copies of KTP, passport, utility bills, selfie photographs with ID	Identity verification, AML/KYC legal obligations

4How We Collect Data

We collect personal data through the following channels:

• Direct interactions: Data you provide when registering an account, completing KYC, making a deposit via BCA or OVO, contacting support, or responding to a promotion.
• Automated technologies: Cookies, web beacons, pixel tags, and server logs that collect Technical Data and Usage Data as you navigate the Platform. See Section 8 (Cookies & Tracking) for full details.
• Third-party identity verification providers: Licensed KYC and anti-money laundering (AML) service providers who cross-reference submitted documents against government databases and watchlists.
• Payment processors: Indonesian local bank gateways and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) that share transaction confirmation data with ular88 to credit your account balance.
• Fraud detection services: Third-party fraud and risk-scoring providers that share signals about suspicious behavior patterns associated with your device fingerprint or IP address.

5Legal Basis for Processing

For each category of personal data, ular88 relies on at least one of the following legal grounds for processing:

• Contractual necessity: Processing your Identity, Contact, and Financial Data is necessary to enter into and perform our contract with you (the Member Agreement).
• Legal obligation: Processing KYC Document Data and Financial Data is required to comply with anti-money laundering (AML) regulations and applicable international gaming licence conditions.
• Legitimate interests: Processing Technical Data and Usage Data to detect fraud, prevent unauthorized account access, and improve Platform security and performance — where these interests are not overridden by your privacy rights.
• Consent: Processing data for marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

6How We Use Your Data

ular88 processes your personal data for the following purposes:

• Account creation and management: To register your Member account, authenticate your identity, maintain your Balance, and enable login access to the Platform.
• Payment processing: To process deposits via BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, and LinkAja; to process withdrawals to your verified bank account or e-wallet; to reconcile transactions; and to generate account statements.
• KYC and compliance: To verify your age (21+ requirement), confirm identity, satisfy anti-money laundering (AML) and counter-terrorism financing (CTF) obligations, and comply with regulatory reporting requirements under our international gaming licence.
• Security and fraud prevention: To detect and prevent unauthorized account access, bonus abuse, collusion, match-fixing, payment fraud, and other prohibited conduct described in our Terms & Conditions.
• Responsible gaming: To monitor betting patterns for signs of problem gambling, enforce deposit limits and loss limits set by the Member, facilitate self-exclusion requests, and provide reality checks in accordance with our Responsible Gaming obligations.
• Customer support: To respond to inquiries via live chat and email, resolve disputes, investigate reported technical issues, and improve service quality through support transcript analysis.
• Marketing communications: To send promotional offers, bonus notifications, and newsletters via email or SMS where you have opted in to receive such communications. You may unsubscribe at any time by clicking the "unsubscribe" link in any marketing email or contacting support.
• Platform improvement: To analyze Usage Data to identify popular features, optimize game loading times, improve mobile responsiveness, and develop new betting markets based on Indonesian player preferences (such as expanded coverage of BRI Liga 1, AFF Cup, and togel variants).
• Legal proceedings: To defend against claims, enforce our Terms & Conditions, and cooperate with law enforcement or regulatory investigations where legally compelled to do so.

7Data Sharing and Disclosure

ular88 does not sell personal data to third parties. We share data only with the following categories of recipients, and only to the extent necessary for the purposes described:

7.1 Service Providers

Third-party service providers that process data on our behalf under strict data processing agreements:

• Payment processors: Indonesian bank gateways (BCA, BRI, BNI, Mandiri networks) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) to facilitate deposits and withdrawals.
• KYC and identity verification: Licensed providers that verify ID documents against government databases and perform AML screening checks.
• Cloud hosting and infrastructure: Data center operators that host our servers, databases, and backup systems under ISO 27001 standards.
• Fraud detection and cybersecurity: Third-party fraud-scoring engines, DDoS mitigation providers, and security monitoring services.
• Game studios and content providers: Evolution Gaming, Pragmatic Play, Microgaming, NetEnt, and other licensed game suppliers that receive minimal technical session data to deliver live casino and slot game content.
• Customer support platform: The live chat and ticket management system provider that processes Communications Data to enable real-time support.

7.2 Regulatory and Law Enforcement Authorities

We may disclose personal data to gaming regulators, financial crime enforcement agencies, and law enforcement authorities where:

• We are required to do so by law or court order;
• We reasonably believe disclosure is necessary to detect, prevent, or report suspected money laundering, fraud, or other criminal activity;
• We are legally obligated under our gaming licence to report suspicious transactions or account activity.

7.3 Business Transfers

In the event that ular88 undergoes a merger, acquisition, asset sale, or other corporate restructuring, personal data may be transferred to the acquiring entity. Members will be notified via email of any such transfer at least 30 days in advance, and the acquiring entity will be contractually bound to honor this Privacy Policy.

8Cookies and Tracking Technologies

ular88 uses cookies, web beacons, and similar tracking technologies to enhance your experience on the Platform. A cookie is a small text file stored on your device that allows us to recognize you on subsequent visits.

8.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the operation of the Platform (e.g., session authentication, load balancing). These cannot be disabled without breaking core functionality.
• Performance Cookies: Collect anonymous usage statistics to help us understand how visitors interact with the Platform and identify technical issues.
• Functional Cookies: Remember your preferences such as language, timezone (WIB/WITA/WIT), and display settings.
• Targeting/Advertising Cookies: Used to deliver relevant promotions based on your activity. These are only set if you consent via the cookie banner.

8.2 Managing Cookies

You can manage cookie preferences through your browser settings. Disabling cookies may limit certain Platform features. Most modern browsers allow you to:

• Block all cookies by default;
• Delete cookies automatically when you close the browser;
• Allow cookies only from trusted sites.

Instructions for managing cookies are available in your browser's help menu (Chrome, Firefox, Safari, Edge).

9Data Retention

ular88 retains personal data for as long as necessary to fulfill the purposes for which it was collected, or to comply with legal and regulatory obligations. Specific retention periods are as follows:

• Active account data: Retained for the duration of your membership and for 90 days after voluntary account closure to process pending withdrawals and resolve disputes.
• KYC documentation: Retained for seven (7) years from the date of account closure to comply with AML and financial crime legislation.
• Transaction records: Retained for seven (7) years from the date of the transaction to comply with financial recordkeeping requirements.
• Support communications: Retained for three (3) years from the date of the last interaction to allow for reopening of resolved tickets and quality assurance.
• Marketing data (where consent-based): Retained until you withdraw consent, at which point your contact details are suppressed from marketing lists within 48 hours.
• Technical and usage logs: Retained for twelve (12) months for security monitoring and platform analytics, then anonymized or deleted.

After the applicable retention period expires, personal data is securely deleted or anonymized such that it can no longer identify you as an individual.

10Data Security Measures

ular88 implements industry-standard technical and organizational measures to protect personal data against unauthorized access, disclosure, alteration, or destruction:

• Encryption in transit: 256-bit SSL/TLS encryption for all data transmitted between your device and our servers.
• Encryption at rest: Database-level encryption (AES-256) for all stored personal data, including KYC documents and financial records.
• Access controls: Role-based access restrictions ensure that only authorized personnel with a legitimate business need can access Member data. All access is logged and audited.
• Two-factor authentication: Available to all Members for account login. Strongly recommended for accounts holding significant balances or frequent withdrawal activity.
• Intrusion detection and prevention: 24/7 automated monitoring for unauthorized access attempts, DDoS attacks, and malware.
• Regular penetration testing: Third-party security audits conducted quarterly to identify and remediate vulnerabilities.
• Secure development practices: Code reviews, vulnerability scanning, and adherence to OWASP Top 10 security principles in all Platform updates.
• Employee training: All ular88 staff with access to personal data undergo mandatory data protection training and sign confidentiality agreements.

Despite these safeguards, no online system can guarantee absolute security. Members are responsible for maintaining the confidentiality of their own account credentials and must notify ular88 immediately if they suspect unauthorized access to their account.

11Your Privacy Rights

Subject to applicable data protection law (including Indonesia's PDP Law where applicable), you have the following rights regarding your personal data:

• Right of access: You may request a copy of all personal data we hold about you, delivered in a structured, commonly used electronic format.
• Right of rectification: You may request correction of inaccurate or incomplete data. You can update most account information directly via your account settings.
• Right to erasure ("right to be forgotten"): You may request deletion of your personal data where (a) it is no longer necessary for the purposes for which it was collected, (b) you withdraw consent on which processing was based, or (c) you object to processing and no overriding legitimate grounds exist. Note that we may be legally required to retain certain data (e.g., KYC documents, transaction records) for the periods specified in Section 9.
• Right to restriction of processing: You may request that we limit processing to storage only in specific circumstances (e.g., while we verify the accuracy of disputed data).
• Right to data portability: You may request transfer of your data to another service provider in a machine-readable format, where technically feasible.
• Right to object: You may object to processing based on legitimate interests or for direct marketing purposes. Marketing opt-out is always honored immediately.
• Right to withdraw consent: Where processing is based on consent (e.g., marketing communications), you may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.
• Right to lodge a complaint: You may lodge a complaint with a supervisory data protection authority in your jurisdiction if you believe your privacy rights have been violated.

To exercise any of these rights, contact our Data Protection team at [email protected] or via live chat. We will respond to your request within 30 days. Proof of identity may be required.

12Minors and Age Restriction

The ular88 Platform is strictly restricted to individuals aged 21 years or older. We do not knowingly collect personal data from persons under the age of 21. All account registrations are subject to age verification through KYC processes.

If we become aware that we have inadvertently collected data from a person under 21, we will immediately suspend the account, void all bets and bonuses, refund any deposited funds (less any winnings obtained in breach of our age restriction), and delete all associated personal data.

Parents or guardians who believe their child has provided personal data to ular88 should contact us immediately at [email protected].

13International Data Transfers

ular88 operates internationally and stores data on servers located outside Indonesia. Personal data may be transferred to and processed in jurisdictions where data protection laws differ from those in Indonesia.

Where data is transferred internationally, we ensure adequate safeguards are in place through:

• Standard Contractual Clauses (SCCs) approved by relevant data protection authorities;
• Hosting infrastructure in jurisdictions recognized as offering adequate data protection;
• Binding Corporate Rules for intra-group transfers where applicable.

By using the ular88 Platform, you acknowledge and consent to the international transfer of your personal data as described in this Policy.

14Third-Party Websites and Services

The ular88 Platform may contain links to third-party websites (e.g., game studio sites, payment provider portals, responsible gaming resources) for your convenience. ular88 is not responsible for the privacy practices of these external sites. We encourage you to review the privacy policies of any third-party site you visit.

This Privacy Policy applies solely to personal data collected by ular88 through the Platform at https://ular88.cam and does not govern data collected by third parties, even if accessed via a link from our Platform.

15Policy Amendments

ular88 reserves the right to amend this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. Where amendments are material, we will notify Members via email to the registered email address and/or via a prominent notice on the Platform at least 14 days before the changes take effect.

The most current version of this Privacy Policy is always available at https://ular88.cam/privacy-policy. The "Last Updated" date at the top of this page indicates when the most recent revision was published.

Continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree to the changes, you must stop using the Platform and may request account closure in accordance with Section 11.

16Contact and Data Protection Officer

For any questions, concerns, or requests related to this Privacy Policy or the processing of your personal data, please contact ular88's Data Protection team:

• Email: [email protected] (Subject line: "Privacy Inquiry" or "Data Subject Request")
• Live Chat: Available 24/7 on the Platform with Indonesian and English-speaking agents
• Response Time: Privacy inquiries are acknowledged within 48 hours. Subject access requests and data deletion requests are completed within 30 days.

ular88 takes all privacy concerns seriously and is committed to working with you to resolve any complaint in a fair and timely manner.