Privacy Policy

1. Introduction

naga91 ("we", "us", "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our online gaming platform at https://naga91.cam. This policy applies to all users of naga91 services, including visitors to our website, registered account holders, and anyone who interacts with our platform.

We recognize that when you provide us with information about yourself, you trust us to handle it responsibly. This Privacy Policy is designed to help you understand what information we collect, why we collect it, how we use it, and what choices you have regarding your information. By using naga91 services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern your use of naga91 services. If you do not agree with this Privacy Policy, you must not use our services. We encourage you to review this policy periodically as we may update it from time to time to reflect changes in our practices, technologies, legal requirements, or other factors.

2. Data Controller

For the purposes of applicable data protection laws, naga91 is the data controller responsible for your personal information. As data controller, we determine the purposes and means of processing your personal data and are responsible for ensuring such processing complies with applicable data protection regulations.

Our Data Protection Officer oversees compliance with privacy laws and can be contacted regarding any privacy concerns, data subject requests, or questions about how we handle your personal information. Contact details are provided in the Contact Information section of this policy.

3. Information We Collect

naga91 collects several types of information to provide and improve our services. The categories of personal data we collect include:

3.1 Information You Provide Directly

When you register an account with naga91, you voluntarily provide us with the following information:

• Identity Information: Full legal name, date of birth, gender, nationality, government-issued identification number (KTP / Indonesian National ID or SIM / Driver's License)
• Contact Information: Email address, mobile phone number, residential address, postal code
• Account Credentials: Username, password (stored in encrypted format), security questions and answers
• Financial Information: Bank account details (bank name, account number, account holder name), e-wallet account details (OVO, DANA, GoPay account numbers), payment transaction history
• Verification Documents: Copies of identification documents, proof of address documents, selfie photographs with identification, bank statements or other proof of payment method ownership
• Communication Data: Content of your communications with customer support, feedback, surveys, or promotional correspondence

3.2 Information Collected Automatically

When you access naga91 services, we automatically collect certain information about your device and usage patterns:

• Device Information: Device type (smartphone, tablet, desktop), operating system and version, browser type and version, screen resolution, device identifiers (IMEI, MAC address for fraud prevention only)
• Usage Data: Pages visited, features used, games played, betting history, session duration, click patterns, navigation paths through the website
• Technical Data: IP address, geolocation data (country, city level only), internet service provider, date and time stamps, referring/exit pages
• Gaming Activity: Bets placed, wins and losses, game preferences, wagering patterns, bonus usage, responsible gaming tool settings (deposit limits, session limits, self-exclusion status)

3.3 Information from Third Parties

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

• Payment Providers: BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, OVO, DANA, GoPay, and other payment processors provide transaction confirmation and verification data
• Game Providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and other suppliers provide game outcome data and RTP statistics
• Verification Services: Third-party identity verification services may provide validation data to confirm your identity
• Fraud Prevention Services: Security partners may share information about suspicious activities or known fraudulent accounts

4. How We Use Your Information

naga91 processes your personal data for the following purposes:

4.1 Service Provision

• Creating and managing your gaming account
• Processing deposits and withdrawals through Indonesian banks and e-wallets
• Providing access to casino games, live dealer tables, sports betting markets, and other gaming services
• Tracking your betting history, account balance, and transaction records
• Communicating with you about your account, transactions, or service updates
• Processing bonus claims and applying wagering requirements

4.2 Legal and Regulatory Compliance

• Verifying your age (21+ requirement) and identity through KYC procedures
• Complying with anti-money laundering (AML) regulations and financial reporting obligations
• Maintaining transaction records as required by international gaming regulations
• Responding to legal requests from law enforcement or regulatory authorities
• Preventing underage gambling and ensuring only eligible individuals access our services

4.3 Security and Fraud Prevention

• Detecting and preventing fraudulent activities, account takeovers, and payment fraud
• Identifying multiple accounts or collusion between players
• Monitoring for bonus abuse, software exploitation, or other Terms violations
• Protecting the integrity of games and ensuring fair play
• Securing our platform against cyber attacks, data breaches, and unauthorized access

4.4 Responsible Gaming

• Implementing and enforcing responsible gaming tools (deposit limits, session time limits, loss limits, self-exclusion)
• Monitoring gambling behavior patterns to identify potential problem gambling
• Providing access to responsible gaming resources and support contacts
• Complying with our commitment to prevent gambling addiction and protect vulnerable players

4.5 Service Improvement

• Analyzing usage patterns to improve website navigation, game selection, and user experience
• Conducting market research and gathering feedback to enhance our services
• Developing new features, games, and payment methods based on user preferences
• Optimizing platform performance, load times, and mobile compatibility

4.6 Marketing Communications (with your consent)

• Sending promotional offers, bonus announcements, and tournament invitations
• Providing personalized game recommendations based on your preferences
• Notifying you about new games from Pragmatic Play, Evolution Gaming, and other providers
• Sharing updates about BRI Liga 1 betting markets, Indonesian holiday promotions, or special events

You may opt out of marketing communications at any time by contacting support or using the unsubscribe link in our emails.

5. Legal Basis for Processing

naga91 processes your personal data based on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contract with you (Terms & Conditions) and provide gaming services you have requested
• Legal Obligation: Processing is required to comply with legal and regulatory obligations including age verification, KYC/AML requirements, and financial reporting
• Legitimate Interests: Processing serves our legitimate business interests in fraud prevention, security, service improvement, and ensuring fair play, provided these interests do not override your fundamental rights
• Consent: For marketing communications and certain tracking technologies, we rely on your explicit consent which you may withdraw at any time

6. Information Sharing

naga91 does not sell your personal data to third parties. We share your information only in the following limited circumstances:

6.1 Service Providers

We share data with trusted third-party service providers who assist in operating our platform:

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) receive your financial information to process deposits and withdrawals
• Game Suppliers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and other game providers receive gameplay data to operate games and calculate outcomes
• Identity Verification Services: Third-party KYC providers process your identification documents to verify your identity and age
• Cloud Hosting: Secure server providers host our platform and databases containing your information
• Customer Support Tools: Live chat and email support platforms store communication records

All service providers are contractually bound to protect your data and use it only for the purposes we specify.

6.2 Legal Requirements

We may disclose your information to comply with legal obligations, including:

• Responding to valid legal requests from law enforcement or regulatory authorities
• Complying with court orders, subpoenas, or legal processes
• Reporting suspicious transactions to anti-money laundering authorities
• Protecting our legal rights in disputes or litigation

6.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity. We will notify you of any such change and ensure the new entity continues to protect your data in accordance with this Privacy Policy.

7. Data Security

naga91 implements comprehensive security measures to protect your personal information:

7.1 Technical Security

• Encryption: All data transmissions between your device and our servers use 256-bit SSL/TLS encryption, the same standard used by banks
• Secure Storage: Personal data is stored on secure servers with restricted access, located in facilities with physical security controls
• Password Protection: Account passwords are hashed using industry-standard algorithms; we cannot view your plain-text password
• Firewalls: Network-level firewalls protect against unauthorized access and cyber attacks
• Regular Audits: Security audits and vulnerability assessments are conducted regularly by third-party experts

7.2 Organizational Security

• Access Controls: Only authorized personnel with legitimate business need can access personal data
• Staff Training: Employees receive data protection training and sign confidentiality agreements
• Incident Response: We maintain an incident response plan to quickly address any potential data breaches
• Monitoring: Automated systems monitor for suspicious access patterns and unauthorized activity

7.3 Your Responsibility

You also play a role in protecting your data. You should:

• Choose a strong, unique password and change it periodically
• Never share your password with anyone
• Log out after each session, especially on shared devices
• Report any suspected unauthorized access immediately
• Keep your email account secure as it's used for account recovery

8. Data Retention

naga91 retains your personal data for as long as necessary to fulfill the purposes described in this Privacy Policy:

Data Type	Retention Period	Reason
Account Information	Duration of account + 7 years	Legal and regulatory requirements
Transaction Records	7 years from transaction date	Financial reporting and AML compliance
Identification Documents	Duration of account + 7 years	Regulatory obligations and dispute resolution
Gaming Activity	Duration of account + 7 years	Dispute resolution and fraud prevention
Marketing Consents	Until consent withdrawn	Consent management
Support Communications	3 years from last contact	Customer service quality and dispute resolution
Website Usage Data	24 months	Analytics and service improvement

After retention periods expire, we securely delete or anonymize your personal data. In some cases, we may retain anonymized data indefinitely for statistical purposes, as this data cannot identify you.

9. Your Privacy Rights

Under applicable data protection laws, Indonesian residents and other users have the following rights regarding their personal data:

9.1 Right to Access

You have the right to request a copy of the personal data we hold about you. This includes your account information, transaction history, gaming activity, and communication records. We will provide this data in a commonly used electronic format within 30 days of your request.

9.2 Right to Correction

If any personal data we hold about you is inaccurate or incomplete, you have the right to request correction. You can update most account information directly through your account settings, or contact customer support for assistance.

9.3 Right to Deletion

You may request deletion of your personal data, subject to certain exceptions. We must retain data if required for legal compliance, dispute resolution, or fraud prevention. For data we can delete, we will do so within 30 days of your request.

9.4 Right to Restriction

You can request that we restrict processing of your personal data in certain circumstances, such as when you contest data accuracy or object to processing. During restriction, we will store but not actively use your data.

9.5 Right to Data Portability

You have the right to receive your personal data in a structured, machine-readable format and transmit it to another service provider. This applies to data you provided to us and data processed based on consent or contract.

9.6 Right to Object

You may object to processing based on legitimate interests, including marketing communications and profiling. We will stop such processing unless we have compelling legitimate grounds that override your interests.

9.7 Right to Withdraw Consent

Where processing is based on consent (such as marketing emails), you may withdraw consent at any time. This does not affect the lawfulness of processing before consent withdrawal.

9.8 How to Exercise Your Rights

To exercise any of these rights, contact our Data Protection Officer at [email protected] with your request. We will verify your identity and respond within 30 days. There is no fee for exercising these rights unless requests are manifestly unfounded or excessive.

10. Cookies and Tracking Technologies

naga91 uses cookies and similar tracking technologies to enhance your experience and analyze platform usage.

10.1 What Are Cookies

Cookies are small text files stored on your device when you visit our website. They help us recognize your device, remember your preferences, and provide personalized features.

10.2 Types of Cookies We Use

• Essential Cookies: Necessary for platform functionality, including maintaining your login session, remembering language preferences, and enabling secure transactions. These cannot be disabled.
• Performance Cookies: Collect information about how you use naga91, such as pages visited and errors encountered. This helps us improve platform performance.
• Functionality Cookies: Remember your preferences like game favorites, viewing options, and notification settings to provide a personalized experience.
• Analytics Cookies: Help us understand user behavior, measure traffic, and analyze which features are most popular. We use this data to improve our services.

10.3 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to refuse cookies or delete existing cookies. However, disabling essential cookies may affect platform functionality and prevent you from using certain features.

11. International Data Transfers

naga91 primarily operates within Indonesia and stores data on servers located in secure facilities. However, some service providers (game suppliers, payment processors, cloud hosting) may be located outside Indonesia. When we transfer personal data internationally, we ensure appropriate safeguards are in place:

• Standard Contractual Clauses approved by data protection authorities
• Adequacy decisions recognizing equivalent data protection standards
• Service provider certifications demonstrating compliance with international privacy frameworks

We require all international service providers to implement security measures equivalent to those we maintain and use your data only for the purposes we specify.

12. Children's Privacy

naga91 services are intended exclusively for adults aged 21 years and older. We do not knowingly collect personal information from individuals under 21. If we discover that we have inadvertently collected data from someone under 21, we will immediately delete that information and terminate the associated account. Parents or guardians who believe their child has provided us with personal information should contact us immediately at [email protected].

13. Changes to This Privacy Policy

naga91 may update this Privacy Policy periodically to reflect changes in our practices, technologies, legal requirements, or other factors. We will notify you of material changes by:

• Posting a prominent notice on our website
• Sending an email to your registered email address
• Displaying a notification when you log in to your account

The "Effective Date" at the top of this policy indicates when it was last revised. Your continued use of naga91 services after changes become effective constitutes acceptance of the updated Privacy Policy. We encourage you to review this policy periodically to stay informed about how we protect your data.

14. Contact Information

If you have questions, concerns, or complaints about this Privacy Policy or how naga91 handles your personal data, please contact us:

For general customer support inquiries not related to privacy, you can also contact us via:

• Live Chat: Available 24/7 from the website bottom-right corner
• WhatsApp: +62 812 3456 7890 (Daily 08:00-00:00 WIB)

We take your privacy seriously and will investigate all concerns thoroughly. If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.