Privacy Policy

1. Introduction

spot63 ("we", "us", "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, share, and protect personal information about our users ("you", "your") when you access or use our online gaming platform at https://spot63.cam (the "Platform"). This policy applies to all personal data processed by spot63 in connection with our services, including casino games, sports betting, account management, payment processing, and customer support.

By creating an account on spot63, accessing the Platform, or using any of our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein. If you do not agree with this Privacy Policy, please do not use our services.

2. Data Controller

For the purposes of applicable data protection laws, spot63 is the data controller responsible for your personal information. We determine the purposes and means of processing your personal data. As data controller, we are responsible for ensuring that your personal information is processed lawfully, fairly, and transparently, and that appropriate technical and organizational measures are in place to protect your data.

If you have any questions, concerns, or requests regarding the processing of your personal data, please contact our Data Protection Officer using the contact details provided at the end of this Privacy Policy.

3. Information We Collect

spot63 collects several categories of personal information to provide, maintain, and improve our services. The types of information we collect include:

3.1 Information You Provide Directly

• Account Registration Information: When you create an account, we collect your full name, date of birth, gender, residential address, email address, mobile phone number, and chosen username and password.
• Identity Verification Documents: To comply with Know Your Customer (KYC) and anti-money laundering regulations, we may collect copies of government-issued identification documents such as your KTP (Indonesian identity card), passport, or driver's license, as well as proof of address documents like utility bills or bank statements.
• Payment Information: We collect bank account details (account number, bank name, account holder name), e-wallet information (OVO, DANA, GoPay account details), and transaction history for deposits and withdrawals. Note that we do not store full credit or debit card numbers.
• Communication Records: When you contact customer support via live chat, email, WhatsApp, or in-app messaging, we collect the content of your communications, including any attachments or screenshots you provide.
• Marketing Preferences: We collect your communication preferences regarding promotional emails, SMS messages, and push notifications.

3.2 Information Collected Automatically

• Device and Technical Information: We automatically collect information about your device including IP address, browser type and version, operating system, device type (mobile, tablet, desktop), screen resolution, and unique device identifiers.
• Usage Data: We collect information about how you interact with the Platform, including pages visited, games played, bets placed, bet amounts, win/loss records, session duration, click patterns, and navigation paths.
• Location Information: We collect your approximate geographic location based on your IP address to ensure compliance with jurisdictional restrictions and to prevent fraud.
• Cookies and Similar Technologies: We use cookies, web beacons, pixel tags, and similar tracking technologies to collect information about your browsing behavior and preferences. See Section 10 for detailed information about cookies.

3.3 Information from Third Parties

• Payment Processors: We receive transaction confirmation and payment status information from Indonesian banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja).
• Game Providers: We receive gameplay data and results from third-party game providers such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, and others to maintain accurate account balances and gaming records.
• Fraud Prevention Services: We may receive information from third-party fraud detection and prevention services to protect against fraudulent activities and ensure Platform security.

4. How We Use Your Information

spot63 processes your personal information for the following purposes:

• Account Management: To create and maintain your account, authenticate your identity, process your registration, and provide access to our services.
• Service Provision: To enable you to play casino games, place sports bets, access live dealer tables, participate in tournaments, and use all features of the Platform.
• Payment Processing: To process deposits and withdrawals, verify payment methods, prevent payment fraud, and maintain accurate financial records.
• Customer Support: To respond to your inquiries, resolve technical issues, handle complaints, provide assistance with account verification, and improve our customer service quality.
• Security and Fraud Prevention: To protect against unauthorized access, detect and prevent fraud, money laundering, and other illegal activities, monitor for suspicious behavior, and enforce our Terms and Conditions.
• Regulatory Compliance: To comply with legal obligations including KYC and anti-money laundering requirements, age verification, responsible gaming obligations, and reporting requirements to regulatory authorities.
• Marketing and Communications: To send you promotional offers, bonus notifications, game recommendations, newsletters, and other marketing communications (with your consent where required). You may opt out of marketing communications at any time.
• Platform Improvement: To analyze usage patterns, conduct research and development, test new features, improve user experience, optimize game selection, and enhance Platform functionality.
• Responsible Gaming: To monitor gambling behavior, identify potential problem gambling indicators, implement deposit limits and self-exclusion measures, and provide support resources.
• Dispute Resolution: To investigate and resolve disputes, respond to legal claims, and cooperate with law enforcement or regulatory investigations.

5. Legal Basis for Processing

spot63 processes your personal information on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contract with you (i.e., to provide gaming services, process payments, and manage your account) as set forth in our Terms and Conditions.
• Legal Obligation: Processing is necessary to comply with legal obligations including KYC requirements, anti-money laundering laws, age verification mandates, tax reporting obligations, and cooperation with regulatory authorities.
• Legitimate Interests: Processing is necessary for our legitimate interests or those of third parties, including fraud prevention, security monitoring, business analytics, platform improvement, and direct marketing (where not overridden by your fundamental rights).
• Consent: Where processing is based on consent (such as for certain marketing communications or optional data collection), you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

6. Data Sharing and Disclosure

spot63 does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information with the following categories of recipients for legitimate business and legal purposes:

6.1 Service Providers and Partners

• Payment Processors: We share necessary payment information with Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to process deposits and withdrawals.
• Game Providers: We share account and gameplay data with third-party game providers (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Play'n GO, Spribe, Pocket Games Soft, and others) to deliver casino games and sports betting services.
• Technology and Infrastructure Providers: We share information with cloud hosting providers, content delivery networks, database management services, and IT security vendors who support our Platform operations.
• Customer Support Platforms: We share communication data with live chat software providers, email service providers, and customer relationship management systems to deliver support services.
• Analytics and Marketing Services: We share usage data with analytics platforms and marketing automation tools to analyze Platform performance and deliver targeted communications (with appropriate safeguards and anonymization where possible).

6.2 Legal and Regulatory Disclosure

We may disclose your personal information to regulatory authorities, law enforcement agencies, courts, or other governmental bodies when required by law, legal process, or legitimate request, or to:

• Comply with legal obligations, court orders, or regulatory requirements
• Enforce our Terms and Conditions or other agreements
• Protect the rights, property, or safety of spot63, our users, or the public
• Investigate and prevent fraud, security breaches, or other illegal activities
• Respond to claims of rights infringement or violation of applicable laws

6.3 Business Transfers

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

6.4 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you with third parties for business, marketing, research, or other purposes. Such data is not considered personal information.

7. Data Security

spot63 takes the security of your personal information seriously and has implemented comprehensive technical and organizational measures to protect your data against unauthorized access, loss, destruction, alteration, or disclosure. Our security measures include:

• Encryption: We use industry-standard SSL/TLS encryption (256-bit) to protect data transmitted between your device and our servers. All sensitive data stored in our databases is encrypted at rest.
• Access Controls: Access to personal information is restricted to authorized personnel on a need-to-know basis. All employees and contractors with access to personal data are bound by confidentiality obligations.
• Network Security: Our infrastructure is protected by firewalls, intrusion detection systems, and regular security monitoring to prevent unauthorized access and cyber attacks.
• Secure Data Centers: Our data is stored in secure, certified data centers with physical access controls, 24/7 monitoring, backup power systems, and disaster recovery capabilities.
• Regular Security Audits: We conduct regular security assessments, penetration testing, and vulnerability scans to identify and address potential security risks.
• Secure Payment Processing: Payment information is processed through PCI-DSS compliant payment gateways. We do not store full credit card numbers or sensitive payment credentials.
• Account Security Features: User accounts are protected by password authentication. We encourage you to use strong, unique passwords and enable any available two-factor authentication features.

While we strive to protect your personal information using the highest security standards, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, and you acknowledge and accept this inherent risk when using the Platform.

8. Data Retention

spot63 retains your personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements. Specific retention periods vary depending on the type of data and applicable legal requirements:

After the applicable retention period expires, we will securely delete or anonymize your personal information. In some cases, we may retain limited information in anonymized or aggregated form for statistical and research purposes, which cannot be used to identify you.

9. Your Privacy Rights

Depending on your location and applicable data protection laws, you may have the following rights regarding your personal information:

• Right of Access: You have the right to request access to the personal information we hold about you and receive a copy of such data.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal information.
• Right to Erasure: You have the right to request deletion of your personal information in certain circumstances, subject to legal and regulatory retention requirements.
• Right to Restriction of Processing: You have the right to request that we restrict processing of your personal information in certain situations.
• Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that data to another controller.
• Right to Object: You have the right to object to processing of your personal information based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory data protection authority if you believe your rights have been violated.

To exercise any of these rights, please contact us using the contact information provided in Section 14. We will respond to your request within one month (or as required by applicable law). In some cases, we may need to verify your identity before processing your request. Note that certain rights may be subject to legal limitations or exemptions.

10. Cookies and Tracking Technologies

spot63 uses cookies, web beacons, pixel tags, and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver personalized content. A cookie is a small text file stored on your device that helps us recognize you on subsequent visits.

10.1 Types of Cookies We Use

• Essential Cookies: Necessary for the Platform to function properly. These cookies enable core functionality such as account login, session management, and secure access to member areas. You cannot opt out of essential cookies.
• Performance Cookies: Collect information about how you use the Platform, such as pages visited and error messages encountered. These cookies help us improve Platform performance and user experience.
• Functional Cookies: Remember your preferences and settings (such as language, currency, and display options) to provide a more personalized experience.
• Marketing Cookies: Track your browsing activity to deliver relevant advertisements and promotional content. These cookies may be set by third-party advertising partners.
• Analytics Cookies: Help us understand user behavior, measure Platform traffic, and analyze trends to improve our services.

10.2 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can configure your browser to reject all cookies, accept only certain cookies, or notify you when a cookie is set. Please note that blocking or deleting cookies may impact Platform functionality and your user experience. Disabling essential cookies will prevent you from accessing certain features or services.

11. International Data Transfers

spot63 operates internationally, and your personal information may be transferred to, stored in, and processed in countries outside of Indonesia where our servers, service providers, and partners are located. These countries may have data protection laws that differ from those in Indonesia.

When we transfer your personal information internationally, we ensure appropriate safeguards are in place to protect your data, including:

• Transferring data only to countries recognized as providing adequate data protection
• Implementing standard contractual clauses approved by regulatory authorities
• Ensuring service providers and partners maintain appropriate security standards
• Conducting regular assessments of data protection measures

By using spot63 services, you acknowledge and consent to the international transfer of your personal information as described in this Privacy Policy.

12. Children's Privacy

spot63 services are intended exclusively for individuals who are at least 21 years of age. We do not knowingly collect, use, or disclose personal information from individuals under 21 years of age. Our registration process includes age verification measures, and we require users to certify that they meet the minimum age requirement.

If we become aware that we have collected personal information from an individual under 21 years of age, we will take immediate steps to delete such information from our systems and close the associated account. Any winnings or deposits associated with underage accounts will be forfeited.

If you believe that we have inadvertently collected information from someone under 21 years of age, please contact us immediately using the contact details provided in Section 14.

13. Changes to This Privacy Policy

spot63 reserves the right to modify, update, or amend this Privacy Policy at any time to reflect changes in our practices, technologies, legal requirements, or other operational considerations. When we make material changes to this Privacy Policy, we will notify you by:

• Posting a prominent notice on the Platform homepage
• Sending an email notification to the email address associated with your account
• Displaying a pop-up notification when you next log in
• Updating the "Last Updated" date at the top of this Privacy Policy

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information. Your continued use of the Platform after the effective date of any changes constitutes your acceptance of the revised Privacy Policy. If you do not agree with any changes, you must cease using the Platform and close your account.

14. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, or if you wish to exercise your privacy rights, please contact us:

• Email: [email protected]
• Data Protection Officer Email: [email protected]
• Live Chat: Available 24/7 on the spot63 platform
• In-App Messaging: Accessible through your account dashboard

We aim to respond to all privacy-related inquiries within 30 days. For complex requests, we may require additional time and will keep you informed of our progress.