Privacy Policy

1. Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information that identifies or could reasonably be used to identify a natural person, directly or indirectly, including but not limited to a name, national identity number, location data, or one or more factors specific to the physical, economic, cultural, or social identity of that person.
• "Processing" means any operation or set of operations performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, transmission, deletion, or destruction.
• "Controller" refers to sbo28, the entity that determines the purposes and means of processing your Personal Data.
• "Player", "You", or "Your" refers to any individual who registers for and accesses the sbo28 platform.
• "Platform" refers to the sbo28 website accessible at sbo28.cam and any associated services.
• "Third-Party Service Providers" refers to payment processors, identity verification vendors, analytics providers, and other entities that assist sbo28 in delivering its services.
• "KYC" (Know Your Customer) refers to the identity and age verification process required for account approval and withdrawal processing.

2. Information We Collect

sbo28 collects Personal Data through several channels: information you provide directly, information generated by your use of the platform, and information received from third-party sources for verification purposes. The categories of information we collect are outlined below.

2.1 Information You Provide Directly

• Registration Data: Full legal name, date of birth, Indonesian national identity card number (NIK / KTP number), email address, mobile phone number, residential address, and city (Jakarta, Surabaya, Bandung, Medan, Bali, or other Indonesian cities).
• KYC Verification Documents: Scanned or photographed copies of your Indonesian identity card (KTP), proof of address documents, and bank account or e-wallet ownership confirmation.
• Financial Information: Bank account details (bank name such as BCA, BRI, BNI, Mandiri, CIMB Niaga, or OCBC NISP; account number; account holder name) and e-wallet account details (OVO, DANA, GoPay, ShopeePay, or LinkAja account identifiers) for processing deposits and withdrawals in Indonesian Rupiah (IDR / Rp).
• Communications: Messages you send to our customer support team via live chat, email, or any other communication channel, including details of your inquiry or complaint.
• Preferences and Feedback: Any preferences you set within your account, survey responses, or feedback you voluntarily provide.

2.2 Information Collected Automatically

• Device and Technical Data: IP address, browser type and version, operating system, device type (smartphone, tablet, desktop), screen resolution, and unique device identifiers.
• Usage Data: Pages and features accessed, time and duration of visits, betting and gaming activity logs, clickstream data, and session information.
• Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking technologies to maintain session state, remember your preferences, and gather analytics. See Section 9 for details on cookie use.
• Transaction Logs: Complete records of all deposits, withdrawals, bets placed, games played, bonuses claimed, and account balance changes.

2.3 Information from Third Parties

• Identity Verification Providers: We may receive confirmation of your identity, age, and address from third-party KYC and fraud-detection services.
• Payment Processors: Payment status confirmations and transaction reference numbers from Indonesian banks and e-wallet providers.
• Fraud and Risk Intelligence: Risk signals and device fingerprint data from fraud prevention partners to protect our platform and players.

3. Legal Basis for Processing

sbo28 processes your Personal Data on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contractual obligations to you, including account management, payment processing, and delivery of gaming services.
• Legal Obligation: Processing is necessary to comply with applicable laws and regulations, including anti-money laundering (AML) requirements, KYC obligations, and financial record-keeping mandates.
• Legitimate Interests: Processing is necessary for our legitimate business interests, including fraud prevention, platform security, customer support, service improvement, and responsible gaming monitoring, provided these interests are not overridden by your rights.
• Consent: For certain processing activities, such as marketing communications and non-essential cookies, we rely on your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

4. How We Use Your Information

We use the Personal Data we collect for the following purposes:

5. How We Share Your Information

sbo28 does not sell, rent, or trade your Personal Data to any third party for their own marketing purposes. We share your information only in the limited circumstances described below:

5.1 Service Providers

We engage trusted third-party service providers who process data on our behalf, strictly for the purposes described in this Privacy Policy and under binding contractual obligations of confidentiality. These include:

• Payment processors and Indonesian banking partners (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja).
• Identity verification and KYC service providers.
• Fraud detection and anti-money laundering screening services.
• Cloud hosting and data storage providers.
• Customer support platform operators.
• Platform analytics providers (using anonymized or pseudonymized data where possible).
• Game software providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft — who may collect limited technical data necessary to deliver their games.

5.2 Legal and Regulatory Disclosure

We may disclose your Personal Data to government authorities, law enforcement agencies, or courts in Indonesia or other relevant jurisdictions when required by law, court order, or regulatory requirement. This includes disclosures required under Indonesian anti-money laundering laws and financial regulations.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of sbo28's business assets, your Personal Data may be transferred to the acquiring entity, subject to the same protections described in this Privacy Policy. We will notify you of any such transfer via email or platform notification.

5.4 Consent-Based Sharing

Beyond the circumstances described above, we will share your Personal Data with third parties only with your explicit prior consent.

6. Data Retention

We retain your Personal Data for as long as your account remains active and for a period thereafter as required by applicable law or legitimate business necessity. Specific retention periods include:

• Account and Registration Data: Retained for the duration of your account and for five (5) years following account closure, as required by AML and financial record-keeping regulations.
• KYC Documents: Retained for five (5) years following account closure or the completion of the relevant business relationship.
• Transaction Records: Retained for seven (7) years from the date of the transaction, in compliance with Indonesian financial regulations.
• Customer Support Communications: Retained for three (3) years from the date of the communication.
• Marketing Preferences: Retained until you withdraw consent or request deletion, whichever is earlier.

Upon expiration of the applicable retention period, Personal Data is securely deleted or anonymized in accordance with our data security protocols.

7. Data Security

sbo28 implements industry-standard technical and organizational security measures to protect your Personal Data against unauthorized access, alteration, disclosure, or destruction. Our security measures include:

• Encryption: All data transmitted between your device and our servers is protected by 256-bit SSL/TLS encryption. Sensitive data at rest is encrypted using AES-256 encryption algorithms.
• Access Controls: Personal Data is accessible only to authorized sbo28 personnel who require access to perform their job duties. All access is logged and monitored.
• Secure Infrastructure: Our servers are hosted in secure, certified data centers with physical security controls, redundant power and network connections, and regular security audits.
• Regular Security Assessments: We conduct periodic vulnerability assessments, penetration testing, and security reviews to identify and remediate potential weaknesses.
• Employee Training: All employees with access to Personal Data receive regular training on data protection principles and security best practices.
• Incident Response: We maintain a documented incident response plan to address potential data breaches promptly and minimize impact.

While we employ robust security measures, no internet-based system can be guaranteed to be 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for all activity that occurs under your account. If you suspect unauthorized access to your account, contact customer support immediately.

8. Your Privacy Rights

Under Indonesian data protection principles and international best practices, you have the following rights regarding your Personal Data:

• Right of Access: You may request confirmation of whether we process your Personal Data and obtain a copy of the Personal Data we hold about you.
• Right to Rectification: You may request correction of inaccurate or incomplete Personal Data. You can update most account information directly through your account settings.
• Right to Erasure: You may request deletion of your Personal Data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected. Note that we may be legally required to retain certain information for regulatory compliance.
• Right to Restriction: You may request that we restrict processing of your Personal Data in certain circumstances, such as when you contest the accuracy of the data or object to processing.
• Right to Data Portability: You may request that we provide your Personal Data in a structured, commonly used, machine-readable format and transmit it to another controller where technically feasible.
• Right to Object: You may object to processing of your Personal Data based on legitimate interests or for direct marketing purposes. We will cease such processing unless we have compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please contact our Data Protection team at [email protected] with "Privacy Rights Request" in the subject line. We will respond to your request within 30 days. Verification of your identity may be required before we can process your request.

9. Cookies and Tracking Technologies

sbo28 uses cookies and similar tracking technologies to enhance your experience, maintain session state, analyze platform usage, and deliver personalized content. Cookies are small text files stored on your device by your web browser.

9.1 Types of Cookies We Use

• Essential Cookies: Necessary for the platform to function. These cookies enable core features such as account login, session management, and security. They cannot be disabled without severely impacting platform functionality.
• Functional Cookies: Remember your preferences and settings (language, time zone, display settings) to provide a more personalized experience.
• Analytics Cookies: Collect aggregated, anonymized data about how visitors use the platform, helping us improve performance and user experience.
• Advertising Cookies: Track your browsing habits to deliver personalized promotional offers relevant to your interests. These cookies are only set with your consent.

9.2 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can configure your browser to refuse cookies or to alert you when cookies are being sent. However, disabling essential cookies will impair platform functionality and may prevent you from using certain features. Visit your browser's help documentation for instructions on managing cookie settings.

10. International Data Transfers

Your Personal Data is primarily stored on servers located within Indonesia. In some cases, data may be transferred to and processed in other countries where our service providers operate. When we transfer Personal Data outside Indonesia, we implement appropriate safeguards to ensure your data remains protected in accordance with this Privacy Policy and applicable data protection laws. These safeguards may include standard contractual clauses, adequacy decisions, or other legally recognized transfer mechanisms.

11. Children's Privacy

The sbo28 platform is intended exclusively for individuals aged 21 years and older. We do not knowingly collect Personal Data from anyone under 21 years of age. If we become aware that we have collected Personal Data from a person under 21 without proper age verification, we will take immediate steps to delete such information and close the associated account. If you believe we have inadvertently collected information from someone under 21, please contact us immediately at [email protected].

12. Third-Party Links

The sbo28 platform may contain links to third-party websites or services for informational purposes. We are not responsible for the privacy practices or content of these external sites. When you navigate to a third-party website, you are subject to that website's privacy policy. We encourage you to review the privacy policies of any third-party sites you visit.

13. Changes to This Privacy Policy

sbo28 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes, we will update the "Last Updated" date at the top of this document and notify you via email or prominent platform notification at least 30 days before the changes take effect. Your continued use of the sbo28 platform after the effective date of the revised Privacy Policy constitutes acceptance of the updated terms. We recommend reviewing this Privacy Policy periodically to stay informed about how we protect your information.

14. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection team:

• Email: [email protected] (Please include "Privacy Inquiry" or "Data Protection Request" in the subject line)
• Live Chat: Available 24/7 through the platform for immediate assistance
• Response Time: We aim to acknowledge all privacy-related inquiries within 48 hours and provide a substantive response within 30 days

For formal data protection complaints, you may also have the right to lodge a complaint with the relevant Indonesian data protection authority.