Privacy Policy

1. Introduction

This Privacy Policy describes how kupu23 ("we," "us," or "our") collects, uses, stores, and protects the personal information of users ("you" or "your") who access our online casino and sports betting platform at https://kupu23.cam. By creating an account, depositing funds, placing wagers, or otherwise using kupu23 services, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein.

kupu23 operates as an internationally licensed online gaming platform serving players in Indonesia and other permitted jurisdictions. We are committed to transparency in our data handling practices and compliance with applicable data protection laws and international privacy standards. Your trust is foundational to our relationship, and we take our responsibility to safeguard your personal information seriously.

This Privacy Policy should be read in conjunction with our Terms & Conditions and Responsible Gaming policy, which together form the complete framework governing your use of kupu23 services.

2. Information We Collect

2.1 Information You Provide Directly

When you register for a kupu23 account, we collect the following personal information that you voluntarily provide:

• Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification documents (Indonesian KTP, passport, or driver's license) for age verification and Know Your Customer (KYC) compliance.
• Contact Information: Residential address in Indonesia, email address, mobile phone number, and preferred communication language.
• Account Credentials: Username, password (stored in encrypted form), and security questions/answers for account recovery.
• Financial Information: Bank account details (bank name, account number, account holder name) for BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata, or BSI; e-wallet information (OVO, DANA, GoPay, ShopeePay, LinkAja account IDs); cryptocurrency wallet addresses for Bitcoin, Ethereum, or Tether (USDT) transactions.
• Verification Documents: Copies of government-issued ID, proof of address (utility bills, bank statements), payment method verification documents, and source of funds documentation when required for enhanced due diligence.

2.2 Information Collected Automatically

When you access and use the kupu23 platform, we automatically collect certain technical and usage information:

• Device Information: IP address, device type (desktop, mobile, tablet), operating system, browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited, games played, betting history (wagers, outcomes, winnings, losses), deposit and withdrawal transactions, session duration, click patterns, and navigation paths through the platform.
• Location Data: Geographic location derived from IP address to ensure compliance with jurisdiction restrictions and for fraud prevention purposes. We do not collect precise GPS coordinates.
• Communication Records: Transcripts of customer support conversations (live chat, email, WhatsApp), including any information you share with our support team.
• Marketing Preferences: Whether you have opted in or out of promotional communications, and your interaction with marketing emails (open rates, click rates).

2.3 Information from Third-Party Sources

In certain circumstances, we may receive information about you from third-party sources:

• Payment Processors: Transaction verification data from banks, e-wallet providers, and cryptocurrency networks to confirm successful deposits and withdrawals.
• Identity Verification Services: Age verification, identity authentication, and fraud prevention data from specialized third-party verification providers.
• Game Providers: Gameplay data, including outcomes and results, from third-party casino game developers such as Evolution Gaming, Pragmatic Play, Microgaming, and NetEnt to accurately credit winnings and maintain game integrity.
• Analytics Services: Aggregated and anonymized usage statistics from analytics platforms to help us understand user behavior and improve our services.

3. How We Use Your Information

kupu23 collects and processes your personal information for the following legitimate purposes:

3.1 Service Delivery and Account Management

• Creating and maintaining your kupu23 account
• Processing deposits, withdrawals, and in-platform transactions in Indonesian Rupiah (IDR) or cryptocurrency
• Enabling you to place wagers on casino games, sports betting markets including bandar bola (football bookmaking), and togel lottery draws
• Crediting winnings, processing bonus claims, and applying promotional offers
• Providing customer support and responding to your inquiries through live chat, email, or WhatsApp
• Sending transactional communications such as account confirmations, deposit receipts, withdrawal confirmations, and important service updates

3.2 Legal and Regulatory Compliance

• Verifying your identity and age to ensure you are at least 21 years old (minimum legal age for gambling in Indonesia)
• Conducting Know Your Customer (KYC) verification as required by international gaming licenses and anti-money laundering (AML) regulations
• Detecting and preventing fraud, money laundering, underage gambling, and other illegal activities
• Complying with legal obligations including tax reporting, regulatory audits, and law enforcement requests
• Enforcing our Terms & Conditions and investigating suspected policy violations
• Maintaining responsible gaming controls including deposit limits, self-exclusion management, and problem gambling detection as outlined in our Responsible Gaming policy

3.3 Platform Security and Fraud Prevention

• Monitoring for suspicious account activity, unusual betting patterns, and potential security threats
• Implementing and maintaining 256-bit SSL encryption for all data transmission
• Detecting and blocking unauthorized access attempts, bot activity, and distributed denial-of-service (DDoS) attacks
• Identifying duplicate accounts and bonus abuse schemes
• Protecting against payment fraud and unauthorized transactions

3.4 Service Improvement and Personalization

• Analyzing usage patterns to understand how Indonesian players interact with our platform
• Optimizing game selection, payment methods, and platform features based on player preferences
• Personalizing your experience by recommending games similar to those you've played
• Testing new features and conducting A/B testing to improve user experience
• Ensuring compatibility across devices (desktop, mobile, tablet) for seamless access

3.5 Marketing and Communication (With Your Consent)

• Sending promotional emails about new games, bonuses, and special offers (only if you have opted in)
• Providing personalized bonus offers based on your gameplay history and preferences
• Notifying you about tournaments, jackpots, and major sporting events relevant to Indonesian players (BRI Liga 1, English Premier League, Champions League, FIFA World Cup)
• Sharing responsible gaming resources and tools to help you maintain healthy gambling habits

You can opt out of promotional communications at any time by clicking "unsubscribe" in any marketing email or updating your preferences in your kupu23 account settings.

4. Data Sharing and Disclosure

kupu23 does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information in the following limited circumstances:

4.1 Service Providers

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

• Payment Processors: Banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata, BSI), e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja), and cryptocurrency payment gateways to process your deposits and withdrawals.
• Game Providers: Casino game developers such as Evolution Gaming, Pragmatic Play, Microgaming, NetEnt, Ezugi, Spribe, and Pocket Games Soft who power our gaming library. They receive anonymized gameplay data to ensure fair results.
• Identity Verification Services: Third-party KYC and age verification specialists who confirm your identity, age, and address to prevent fraud and ensure regulatory compliance.
• Customer Support Tools: Live chat platforms and support ticketing systems that enable our 24/7 Indonesian-speaking customer service team to assist you.
• Cloud Infrastructure Providers: Secure hosting and storage services that maintain our servers and databases with enterprise-grade security.

All service providers are contractually obligated to protect your information, use it only for specified purposes, and comply with data protection standards equivalent to those outlined in this policy.

4.2 Legal Requirements

We may disclose your information when legally required to do so:

• In response to valid legal processes such as court orders, subpoenas, or regulatory inquiries
• To comply with anti-money laundering (AML) and counter-terrorism financing (CTF) reporting obligations
• When requested by law enforcement agencies investigating suspected illegal activity
• To protect the rights, property, or safety of kupu23, our users, or the public
• To enforce our Terms & Conditions and investigate violations

4.3 Business Transfers

In the event that kupu23 is involved in a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the acquiring entity. We will notify you via email and prominent notice on our website before such transfer, and the new entity will be required to honor this Privacy Policy.

4.4 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you personally. For example, we may publish statistics about Indonesian player preferences, popular game categories, or average deposit amounts to demonstrate market trends. Such data does not constitute personal information and is not subject to the restrictions in this Privacy Policy.

5. Data Security Measures

kupu23 employs industry-leading security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

5.1 Technical Safeguards

• Encryption: All data transmission between your device and kupu23 servers uses 256-bit SSL/TLS encryption, the same standard used by major financial institutions.
• Password Security: Passwords are hashed using bcrypt or similar one-way cryptographic algorithms and are never stored in plain text. Even kupu23 staff cannot view your password.
• Secure Servers: Our databases are hosted in secure data centers with physical access controls, fire suppression systems, and 24/7 monitoring.
• Firewall Protection: Multi-layered firewalls protect against unauthorized network intrusion and distributed denial-of-service (DDoS) attacks.
• Regular Security Audits: Independent cybersecurity firms conduct quarterly penetration testing and vulnerability assessments to identify and address potential security weaknesses.

5.2 Organizational Safeguards

• Access Controls: Personal information is accessible only to authorized kupu23 employees who require it to perform their job functions (customer support, compliance, security teams). Access is granted on a need-to-know basis.
• Staff Training: All employees receive regular training on data protection principles, security best practices, and confidentiality obligations.
• Confidentiality Agreements: Employees and service providers sign strict confidentiality agreements prohibiting unauthorized disclosure of user information.
• Incident Response Plan: We maintain a documented plan for responding to data breaches, including user notification, regulatory reporting, and remediation procedures.

5.3 Your Security Responsibilities

While kupu23 implements robust security measures, you also play a critical role in protecting your account:

• Use a strong, unique password not shared with other websites
• Never share your password with anyone, including kupu23 customer support staff (we will never ask for it)
• Log out after each session, especially on shared or public devices
• Enable two-factor authentication (2FA) if available for an additional security layer
• Contact support immediately if you notice suspicious account activity
• Keep your registered email address and phone number up to date for security notifications

6. Data Retention and Deletion

6.1 Retention Periods

kupu23 retains your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements:

• Active Accounts: Personal information for active accounts is retained as long as your account remains open and for a reasonable period thereafter to allow for account reactivation.
• Closed Accounts: After you voluntarily close your account, we retain core identity information (name, date of birth, identification documents) for 7 years to comply with anti-money laundering (AML) regulations and licensing requirements.
• Transaction Records: Deposit, withdrawal, and betting history are retained for 7 years for financial auditing, tax reporting, and regulatory compliance purposes.
• Customer Support Records: Communication transcripts are retained for 3 years for quality assurance and dispute resolution.
• Marketing Data: If you opt out of marketing communications, your opt-out preference is retained indefinitely to ensure we honor your request. Other marketing-related data is deleted within 2 years of account closure.

6.2 Data Deletion

After the applicable retention period expires, we securely delete or anonymize your personal information. Deletion methods include cryptographic erasure, physical destruction of storage media, and overwriting with random data to prevent recovery.

You may request deletion of your personal information at any time by contacting our customer support team. However, please note that we may be legally required to retain certain information even after a deletion request (for example, transaction records for tax and AML compliance). In such cases, we will delete all non-required data and restrict the use of retained data to the minimum necessary for legal compliance.

7. Your Privacy Rights

As a kupu23 user, you have the following rights regarding your personal information:

7.1 Right to Access

You have the right to request a copy of the personal information we hold about you. To exercise this right, contact our customer support team. We will provide your data in a structured, commonly used, and machine-readable format (such as CSV or JSON) within 30 days of your request.

7.2 Right to Rectification

If any personal information we hold about you is inaccurate or incomplete, you have the right to request correction. You can update most information directly through your kupu23 account settings, or contact support for assistance with changes that require verification (such as name or date of birth corrections).

7.3 Right to Erasure

You have the right to request deletion of your personal information, subject to legal retention requirements as described in Section 6. We may retain certain data if required by law or necessary for legal claims, but will delete all non-essential information upon request.

7.4 Right to Restrict Processing

You may request that we limit how we use your personal information in certain circumstances, such as while we verify data accuracy or assess whether you have legitimate grounds for erasure. During restriction periods, we will store your data but not actively process it except for specified purposes.

7.5 Right to Object

You have the right to object to processing of your personal information for direct marketing purposes. You can opt out of promotional emails at any time by clicking "unsubscribe" or updating your account preferences. For other processing activities, you may object if you believe we lack legitimate grounds that override your privacy interests.

7.6 Right to Data Portability

You have the right to receive your personal information in a portable format and to transmit it to another service provider. We will provide your data in CSV, JSON, or PDF format as requested.

7.7 Right to Withdraw Consent

Where processing is based on your consent (such as marketing communications or optional cookies), you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

7.8 Exercising Your Rights

To exercise any of these rights, contact our customer support team via live chat, email ([email protected]), or WhatsApp. We will verify your identity and respond to valid requests within 30 days. There is no charge for exercising these rights unless your request is manifestly unfounded or excessive.

8. Cookies and Tracking Technologies

8.1 What Are Cookies

Cookies are small text files placed on your device by websites you visit. They enable websites to remember your preferences, recognize you on return visits, and improve your experience. kupu23 uses cookies and similar technologies (web beacons, pixel tags, local storage) for essential functionality and optional analytics.

8.2 Types of Cookies We Use

8.3 Managing Cookies

Essential cookies are required for kupu23 to function and cannot be disabled. You can control optional cookies (functional, analytics, marketing) through your browser settings. Most browsers allow you to block cookies, delete existing cookies, or receive warnings before cookies are placed. Note that blocking cookies may impact your ability to use certain features of the kupu23 platform.

For more information on managing cookies:

• Google Chrome: Settings → Privacy and Security → Cookies and other site data
• Mozilla Firefox: Settings → Privacy & Security → Cookies and Site Data
• Safari: Preferences → Privacy → Manage Website Data
• Microsoft Edge: Settings → Privacy, search, and services → Cookies and site permissions

9. International Data Transfers

kupu23 operates as an internationally licensed platform with servers located outside Indonesia. When you use our services, your personal information may be transferred to, stored in, and processed in countries where our servers, service providers, and business partners are located. These countries may have data protection laws different from those in Indonesia.

We ensure that all international data transfers are protected by appropriate safeguards, including:

• Contractual clauses with service providers requiring them to protect your information to standards equivalent to those in this Privacy Policy
• Using service providers certified under internationally recognized data protection frameworks
• Implementing technical measures such as encryption for data in transit and at rest
• Conducting due diligence on the security practices of all partners who handle your data

10. Children's Privacy

kupu23 is strictly an adults-only platform. We do not knowingly collect personal information from individuals under 21 years of age, the minimum legal gambling age in Indonesia. Our registration process includes age verification checks, and we conduct periodic re-verification to ensure compliance.

If we discover that we have inadvertently collected information from a person under 21, we will immediately delete that information and close the associated account. Any funds in the account will be returned to the payment method used for deposit after verifying the account holder's identity.

If you believe a minor has created an account on kupu23, please contact our customer support team immediately so we can take appropriate action.

11. Changes to This Privacy Policy

kupu23 reserves the right to update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or service offerings. When we make material changes, we will:

• Update the "Last Updated" date at the top of this policy
• Provide prominent notice on the kupu23 homepage and/or via email to registered users
• For significant changes affecting your rights, obtain your explicit consent where required by law

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of kupu23 after changes become effective constitutes acceptance of the updated policy.

12. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or how kupu23 handles your personal information, please contact us through the following channels:

• Email: [email protected] (for privacy inquiries, use subject line: "Privacy Policy Question")
• Live Chat: Available 24/7 through the kupu23 website (click the chat icon in the bottom right corner)
• WhatsApp: Contact customer support for our official WhatsApp number (verified accounts only)

Our Indonesian-speaking customer support team is available 24 hours a day, 7 days a week. For privacy-specific inquiries, please clearly state that your question relates to data protection, and our specialized privacy team will respond within 48 hours.