spn88 Privacy Policy

spn88 ("we", "us", "our") operates the online gaming platform accessible at https://spn88.one (the "Platform"). We are committed to protecting the personal information of all individuals who interact with our Platform — whether as registered players, prospective registrants, or visitors.

This Privacy Policy has been prepared in accordance with internationally recognised data protection principles, including those reflected in the General Data Protection Regulation (GDPR) framework, and applies to all personal data processed by spn88 in connection with the operation of the Platform and the provision of gaming services to players across Indonesia — including those located in Jakarta, Surabaya, Bandung, Medan, Semarang, Yogyakarta, Bali, Makassar, Palembang, and all other regions of the country.

By creating an account on spn88, or by continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. This Policy should be read in conjunction with our Terms & Conditions.

spn88 acts as the data controller in respect of all personal data collected and processed through the Platform. As data controller, spn88 determines the purposes for which personal data is processed and the means by which processing is carried out.

For all privacy-related enquiries, data subject requests, or complaints, please contact spn88's designated privacy point of contact using the details set out in Section 14 of this Policy.

spn88 collects the following categories of personal data in connection with the registration, operation, and management of player accounts:

3.1 Identity Data

• Full legal name (as it appears on your government-issued identity document)
• Date of birth (used to verify the 21+ age requirement)
• Gender (optional, collected during registration for personalisation purposes only)
• Copies of identity documents submitted during the KYC process, such as your national identity card (KTP), passport, or driver's licence

3.2 Contact Data

• Email address (used for account verification, security alerts, and service communications)
• Mobile telephone number (used for two-factor authentication and account security notifications)
• Residential address in Indonesia (collected as part of the KYC verification process)

3.3 Financial Data

• Bank account details for Indonesian banks including BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, and Bank Permata, as required for deposit and withdrawal processing
• E-wallet identifiers for OVO, DANA, GoPay, ShopeePay, and LinkAja accounts registered in your name
• Transaction history including deposit amounts, withdrawal requests, wager values, and bonus activity
• Records of payment method verification conducted as part of the KYC process

3.4 Technical Data

• IP address and geolocation data derived from your device at the time of each login session
• Device type, operating system, browser type and version, and device identifiers
• Session timestamps, login and logout records, and session duration
• Cookies and similar tracking technologies as described in Section 9

3.5 Usage Data

• Game play history including game titles, wager amounts, win/loss outcomes, and session durations
• Sportsbook betting history including market selections, stake amounts, and settlement outcomes for markets such as mix parlay (multi-leg accumulator) and voor bola (Asian handicap) bets
• Bonus opt-in records and promotional interaction history
• Customer support interaction records including chat transcripts and email correspondence

3.6 Responsible Gaming Data

• Self-imposed deposit limit settings and any modifications made to those limits
• Self-exclusion requests and the duration and status of any active exclusion period
• Session time reminder preferences
• Any responsible gaming-related communications between you and the spn88 support team

spn88 collects personal data through the following channels:

• Direct collection: Data you provide voluntarily during the account registration process, during KYC verification, when making a deposit or withdrawal, when contacting our customer support team, or when completing any other form or survey on the Platform.
• Automated collection: Technical and usage data collected automatically as you navigate and interact with the Platform, including via cookies, web beacons, log files, and session recording technologies.
• Third-party sources: Where permitted, spn88 may receive data from identity verification service providers, fraud prevention agencies, payment processing partners, and game providers to supplement or verify information you have provided directly. Such third-party data sources are subject to their own privacy policies and data-sharing agreements with spn88.
• Public sources: In limited circumstances, spn88 may consult publicly available sources — such as sanctions lists, politically exposed persons (PEP) registers, and adverse media databases — as part of our anti-money-laundering (AML) and know-your-customer (KYC) compliance obligations.

The table below sets out the purposes for which spn88 processes personal data and the corresponding legal basis for each processing activity:

spn88 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share personal data only in the following circumstances, and only to the extent strictly necessary for the stated purpose:

• Payment processors and banking partners: Financial data is shared with Indonesian banking partners (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) solely to execute deposit and withdrawal transactions requested by you.
• Identity verification providers: Identity and contact data may be shared with third-party KYC and AML service providers to fulfil our verification obligations. These providers operate under strict data processing agreements and are prohibited from using your data for any purpose other than verification.
• Game providers: Certain usage data (such as game session identifiers) is shared with licensed game studios — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Pocket Games Soft, and Spribe — to operate game software and ensure correct bet settlement. Game providers do not receive your identity or contact information unless required for their own regulatory compliance.
• Regulatory and law enforcement authorities: spn88 is legally obligated to disclose personal data to relevant authorities where required by applicable law, including in connection with AML investigations, fraud inquiries, or official legal proceedings. spn88 will disclose only the minimum data necessary to satisfy the legal requirement.
• Corporate transactions: In the event of a merger, acquisition, restructuring, or sale of spn88's business or assets, personal data held by spn88 may be transferred to the acquirer or successor entity, subject to equivalent privacy protections being maintained.

spn88 serves players located in Indonesia and processes personal data in connection with an internationally operated gaming platform. As a result, some personal data may be transferred to, stored in, or processed in jurisdictions outside Indonesia. This may include jurisdictions where spn88's infrastructure, game servers, or third-party service providers are located.

Where personal data is transferred internationally, spn88 takes reasonable steps to ensure that an adequate level of data protection is maintained, consistent with the standards applied within Indonesia. This includes implementing appropriate contractual safeguards with third-party data processors located outside Indonesia and applying security controls to cross-border data flows.

spn88 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following retention principles apply:

• Active account data: Personal data associated with an active spn88 account is retained for the duration of the account relationship and for a period of at least 5 years following account closure, in accordance with AML record-keeping requirements.
• Transaction records: Financial transaction records — including deposit history, withdrawal records, and bet settlement data — are retained for a minimum of 5 years following the date of each transaction, or longer where required by applicable law.
• KYC documentation: Identity verification documents submitted during the KYC process are retained for at least 5 years following the end of the account relationship.
• Customer support records: Support interaction records, including live chat transcripts and email correspondence, are retained for a period of 2 years from the date of the interaction, unless the subject matter relates to an ongoing dispute or legal matter, in which case the record is retained until resolution.
• Marketing data: Where you have opted in to marketing communications, your marketing preferences and associated data are retained until you withdraw consent or request deletion, after which marketing data is suppressed within 30 days.
• Technical logs: Server logs, IP address records, and session data are retained for up to 12 months for security monitoring and fraud prevention purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be attributed to any individual.

spn88 uses cookies and similar tracking technologies to operate the Platform efficiently, maintain your session, and improve your overall user experience. The following categories of cookies are used:

• Strictly necessary cookies: These cookies are essential to the functioning of the Platform and cannot be disabled. They include session authentication cookies that keep you logged in during your visit, security tokens that protect against cross-site request forgery (CSRF) attacks, and load-balancing cookies that ensure stable platform performance.
• Functional cookies: These cookies remember your preferences — such as your preferred language settings and game lobby display options — to personalise your experience across sessions.
• Analytics cookies: spn88 uses privacy-respecting analytics tools to collect aggregated, anonymised data on how players navigate the Platform. This data is used exclusively to improve the design and performance of the Platform and is not shared with third-party advertising networks.
• Security and fraud-prevention cookies: These cookies help spn88 detect and prevent fraudulent account activity, including automated bot activity, credential stuffing attacks, and abnormal login patterns.

Most web browsers allow you to control cookie settings through the browser's privacy or security settings menu. Disabling strictly necessary cookies may impair the functionality of the Platform, including your ability to log in and maintain a gaming session.

As a data subject, you hold the following rights in respect of your personal data held by spn88. To exercise any of these rights, please contact us using the details in Section 14. We will respond to all verifiable data subject requests within 30 calendar days of receipt.

spn88 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration, or disclosure:

• 256-bit SSL/TLS encryption: All data transmitted between your device and the spn88 Platform is encrypted using industry-standard 256-bit AES SSL/TLS protocols. This applies to all account pages, login flows, deposit and withdrawal screens, and support interactions.
• Access controls: Access to personal data within spn88's internal systems is restricted on a strict need-to-know basis. Staff members are granted only the minimum data access required for their specific role. All staff with access to personal data undergo mandatory data protection training.
• Login anomaly detection: spn88's security systems continuously monitor for unusual login patterns — including access from unrecognised devices, new geographic locations, or multiple failed authentication attempts — and generate immediate security alerts to your registered contact details.
• Data minimisation: spn88 collects only the personal data strictly necessary for the purposes described in this Policy. We do not collect sensitive data — such as health information or political views — unless directly relevant to a responsible gaming or regulatory compliance matter.
• Incident response: In the event of a personal data breach that poses a risk to your rights and freedoms, spn88 will notify affected individuals without undue delay and will take all reasonable steps to contain and remediate the breach.

spn88 operates a strict minimum age policy. You must be at least 21 years of age to register an account or place any wager on the Platform. We do not knowingly collect personal data from individuals under 21 years of age.

If spn88 becomes aware that personal data has been collected from an individual who is under 21 years of age, we will take the following steps immediately: (a) close the account; (b) delete the collected personal data or anonymise it; (c) return any deposited funds to the source payment method; and (d) forfeit any winnings accumulated in the underage account.

If you are a parent or guardian and believe that your child has registered an account on spn88, please contact our support team immediately at [email protected] so that we can take prompt action.

spn88 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory guidance. When material changes are made, we will notify registered players via email to their registered address and/or via a prominent notice on the Platform.

The "Last Updated" date at the top of this page will be revised with each amendment. We encourage you to review this Policy periodically. Continued use of the Platform following the effective date of any amendment constitutes your acceptance of the updated Policy.

For all privacy-related enquiries, data subject access requests, or complaints regarding spn88's handling of your personal data, please contact us through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week via the spn88 Platform. This is the fastest channel for urgent privacy matters. Indonesian-speaking agents are available at all times.
• Email: [email protected] (plain text — not a clickable link). Please include "Privacy Request" or "Data Subject Request" in the subject line. Target response time: within 24 hours on business days (WIB, UTC+7).
• Response commitment: spn88 will acknowledge all privacy complaints within 48 hours (WIB, UTC+7) and will endeavour to resolve matters within 30 calendar days. Complex matters requiring third-party consultation may take longer; we will keep you informed of progress.

If you are not satisfied with spn88's response to a privacy complaint, you may escalate the matter to the relevant supervisory authority in your jurisdiction or seek independent legal advice.