Privacy Policy

1. Introduction and Scope

This Privacy Policy explains how 3zzk ("we", "us", "our", "the Company") collects, uses, stores, shares, and protects personal information from users ("you", "your", "User", "Player") of our online betting platform and services (the "Platform"). We are committed to safeguarding your privacy and handling your personal data responsibly in compliance with international data protection standards and Indonesian market requirements.

This Privacy Policy applies to all information collected through the 3zzk website, mobile applications, customer service channels, and any other services we provide. By registering an account, accessing the Platform, or using our services, you acknowledge that you have read, understood, and consent to the data practices described in this Privacy Policy. If you do not agree with our privacy practices, please do not use 3zzk services.

We process personal data in accordance with international data protection principles including lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, and confidentiality. This Privacy Policy should be read in conjunction with our Terms and Conditions, which govern your use of the Platform.

2. Data Controller Information

3zzk operates as the data controller for all personal information collected through our Platform. As data controller, we determine the purposes and means of processing your personal data and are responsible for its protection and lawful handling.

For questions, concerns, or requests regarding your personal information or this Privacy Policy, please contact our Data Protection Officer:

• Email: [email protected]
• Subject Line: "Privacy Inquiry" or "Data Protection Request"
• Response Time: We aim to respond to all privacy inquiries within 5 business days

3. Information We Collect

3zzk collects various categories of personal information necessary to provide, maintain, and improve our services, ensure platform security, and comply with legal obligations including anti-money laundering (AML) and Know Your Customer (KYC) regulations.

3.1 Information You Provide Directly

• Account Registration Data: Full legal name (as appearing on Indonesian KTP), date of birth, gender, residential address, email address, mobile phone number, chosen username and password.
• Identity Verification Documents: Indonesian KTP (Kartu Tanda Penduduk) or other government-issued identification, proof of address (utility bills, bank statements), proof of payment method ownership, selfie photographs for identity verification.
• Financial Information: Bank account details (account number, bank name, account holder name), e-wallet account information (OVO, DANA, GoPay, ShopeePay, LinkAja), transaction history including deposits and withdrawals.
• Communication Records: Correspondence with customer support via live chat, email, WhatsApp, or other channels, feedback and survey responses, complaint records.

3.2 Information Collected Automatically

• Account Activity Data: Betting history and patterns, game play records, win/loss statistics, bonus usage, login frequency and duration, platform navigation patterns.
• Technical Information: IP address, device type and model, operating system and version, browser type and version, screen resolution, language preferences, time zone settings (typically WIB for Indonesian users).
• Cookies and Tracking Data: Session cookies for authentication, preference cookies for user settings, analytics cookies for platform performance monitoring. See Section 9 for detailed cookie information.
• Geolocation Data: Approximate location derived from IP address to verify Indonesian residency and comply with jurisdictional restrictions.

3.3 Information from Third-Party Sources

• Payment Processors: Transaction confirmation and status updates from Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga) and e-wallet providers.
• Identity Verification Services: Results from third-party KYC verification providers used to validate Indonesian identity documents.
• Fraud Prevention Services: Risk assessment data from anti-fraud and responsible gaming monitoring services.

4. How We Use Your Information

3zzk processes your personal information for the following specific, legitimate purposes:

4.1 Account Management and Service Provision

• Creating, maintaining, and managing your betting account
• Processing deposits and withdrawals via Indonesian banks and e-wallets
• Recording and settling bets on sports events, casino games, and other gaming products
• Administering bonuses, promotions, and loyalty rewards
• Providing personalized gaming recommendations based on your preferences
• Authenticating your identity during login and sensitive operations

4.2 Legal Compliance and Security

• Verifying your age (minimum 21 years) and Indonesian residency status
• Conducting KYC due diligence as required by anti-money laundering regulations
• Detecting and preventing fraud, collusion, money laundering, and other illegal activities
• Monitoring for problem gambling behaviors and implementing responsible gaming interventions
• Responding to legal requests from law enforcement or regulatory authorities
• Enforcing our Terms and Conditions and protecting 3zzk's legal rights

4.3 Customer Support and Communications

• Responding to your inquiries via live chat, email, WhatsApp, or other support channels
• Providing Indonesian-language customer service during WIB business hours
• Sending transactional notifications about account activity, deposits, withdrawals, and betting outcomes
• Communicating important account updates, security alerts, and policy changes

4.4 Platform Improvement and Analytics

• Analyzing platform usage patterns to improve user experience and interface design
• Conducting statistical analysis of betting trends and gaming preferences
• Testing new features and gaming products
• Monitoring platform performance, uptime, and technical issues
• Developing enhanced security measures and fraud detection algorithms

4.5 Marketing Communications (With Your Consent)

Subject to your consent and opt-in preferences, we may use your contact information to send promotional materials about:

• New gaming products and betting markets (e.g., BRI Liga 1 matches, EPL fixtures, new slots)
• Exclusive bonus offers and promotions for Indonesian players
• Tournaments, competitions, and special events
• Platform updates and new features

You may opt out of marketing communications at any time through your account settings or by clicking unsubscribe links in emails. Opting out does not affect transactional communications necessary for account management.

5. Information Sharing and Disclosure

3zzk does not sell, rent, or trade your personal information to third parties. We share your information only in the following limited circumstances:

5.1 Service Providers and Business Partners

We engage trusted third-party service providers to perform functions on our behalf, including:

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay) for processing deposits and withdrawals
• Identity Verification Services: KYC verification providers for validating Indonesian KTP documents
• Cloud Hosting Providers: Secure data storage and server infrastructure
• Customer Support Tools: Live chat platforms and ticketing systems
• Analytics Providers: Platform performance monitoring and user behavior analysis

All service providers are contractually bound to process your data only for specified purposes, maintain strict confidentiality, and implement appropriate security measures. They may not use your information for their own purposes.

5.2 Legal Obligations and Rights Protection

We may disclose your personal information when required by law or when we believe disclosure is necessary to:

• Comply with legal obligations, court orders, or regulatory requests
• Cooperate with law enforcement investigations of suspected illegal activity
• Protect the safety, rights, or property of 3zzk, our users, or the public
• Detect, prevent, or address fraud, security vulnerabilities, or technical issues
• Enforce our Terms and Conditions or other agreements

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the acquiring entity. We will notify you via email or prominent platform notice before your information becomes subject to a different privacy policy.

5.4 With Your Explicit Consent

We may share your information with third parties not described above if we obtain your explicit, informed consent to do so.

6. Data Security Measures

3zzk employs industry-leading technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

6.1 Technical Security Controls

• SSL/TLS Encryption: All data transmitted between your device and our servers is protected by 256-bit SSL encryption, the same standard used by Indonesian banks for online banking
• Encrypted Data Storage: Sensitive personal data including identity documents and financial information is encrypted at rest using AES-256 encryption
• Secure Password Storage: Passwords are hashed using bcrypt algorithms and never stored in plain text
• Firewall Protection: Multi-layered firewall systems protect our servers from unauthorized access
• Regular Security Audits: Third-party penetration testing and vulnerability assessments conducted quarterly
• DDoS Protection: Advanced protection against distributed denial-of-service attacks

6.2 Organizational Security Measures

• Access to personal data restricted to authorized personnel only on a need-to-know basis
• Mandatory security training for all employees handling personal information
• Confidentiality agreements binding all staff and contractors
• Incident response procedures for data breaches with notification protocols
• Regular backup systems with disaster recovery capabilities

7. Data Retention and Deletion

3zzk retains your personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, and resolve disputes.

7.1 Retention Periods

• Active Accounts: Personal data is retained for the duration of your active account plus 7 years following account closure to comply with financial record-keeping requirements and resolve potential disputes
• Identity Documents: KTP and verification documents retained for 7 years from account closure for AML compliance
• Transaction Records: Deposit, withdrawal, and betting history retained for 7 years for tax, audit, and legal purposes
• Communication Records: Customer support correspondence retained for 3 years
• Marketing Data: Contact information for marketing retained until you withdraw consent, after which it is deleted within 30 days

7.2 Data Deletion Procedures

When retention periods expire or you request deletion (subject to legal exceptions), we permanently erase your personal information using secure deletion methods that render data unrecoverable. Backup systems are purged during routine backup cycles.

8. Your Privacy Rights

Under international data protection standards, you have the following rights regarding your personal information:

8.1 Right of Access

You may request a copy of the personal data we hold about you. We will provide this information in a structured, commonly used, machine-readable format (typically PDF or CSV) within 30 days of your request.

8.2 Right to Rectification

If your personal information is inaccurate or incomplete, you have the right to request corrections. You can update most information directly through your account settings or by contacting customer support.

8.3 Right to Erasure ("Right to Be Forgotten")

You may request deletion of your personal data in certain circumstances. However, we may be legally required to retain certain information for up to 7 years for AML compliance, financial auditing, and dispute resolution purposes.

8.4 Right to Restrict Processing

You may request that we limit how we use your personal information in specific situations, such as while we verify the accuracy of disputed data.

8.5 Right to Data Portability

You may request that we transfer your personal data to another service provider in a structured, machine-readable format where technically feasible.

8.6 Right to Object

You may object to processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, though we may continue processing if we have compelling legitimate grounds.

8.7 Right to Withdraw Consent

Where processing is based on your consent (such as marketing communications), you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

8.8 Exercising Your Rights

To exercise any privacy rights, contact us at [email protected] with subject line "Privacy Rights Request". We will respond within 30 days and may request identity verification to protect your security. There is no charge for exercising your rights unless requests are manifestly unfounded or excessive.

9. Cookies and Tracking Technologies

3zzk uses cookies and similar technologies to enhance platform functionality, analyze usage patterns, and improve user experience.

9.1 Types of Cookies We Use

• Essential Cookies: Strictly necessary for platform operation, authentication, security, and session management. These cannot be disabled as they are required for core functionality.
• Performance Cookies: Collect anonymous information about platform usage, page load times, and error reporting to help us improve performance.
• Functionality Cookies: Remember your preferences such as language selection, favorite game categories, and account settings.
• Analytics Cookies: Help us understand user behavior through aggregated statistics about navigation patterns, popular games, and betting trends.

9.2 Managing Cookie Preferences

You can manage cookie preferences through your browser settings. Note that blocking essential cookies will prevent platform functionality. Most browsers allow you to refuse third-party cookies while accepting first-party cookies necessary for site operation.

10. International Data Transfers

Your personal information may be transferred to and processed on servers located outside Indonesia. When we transfer data internationally, we ensure appropriate safeguards are in place:

• Transfers only to jurisdictions with adequate data protection laws recognized internationally
• Contractual agreements with service providers requiring equivalent data protection standards
• Use of standard contractual clauses approved by data protection authorities
• Encryption during transmission and at rest regardless of server location

11. Children's Privacy Protection

3zzk services are strictly intended for adults aged 21 years or older in accordance with Indonesian legal requirements. We do not knowingly collect personal information from individuals under 21 years of age.

If we discover that we have inadvertently collected personal data from someone under 21, we will immediately delete the account, erase all associated personal information, and forfeit any deposits or winnings. Parents and guardians are responsible for monitoring minors' internet usage to prevent unauthorized access to online gambling platforms.

If you believe we have collected information from someone under 21, please contact us immediately at [email protected] with subject line "Underage Account Report".

12. Policy Updates and Notifications

3zzk reserves the right to modify this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or business operations. When we make material changes that significantly affect your rights, we will:

• Update the "Last Updated" date at the top of this page
• Notify you via email to your registered email address
• Display a prominent notice on the Platform upon your next login
• Request your renewed consent if 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 3zzk services after policy modifications constitutes acceptance of the updated terms.

13. Contact and Complaints

For any questions, concerns, or complaints regarding this Privacy Policy or our data handling practices, please contact our Data Protection Officer:

• Email: [email protected]
• Subject Line: "Privacy Policy Inquiry" or "Data Protection Complaint"
• Available Hours: 24/7 with priority response during WIB business hours (Monday-Friday 9:00-18:00 WIB)
• Language Support: Indonesian and English

We take privacy concerns seriously and will investigate all complaints thoroughly. You can expect an initial response within 5 business days. If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.