Privacy Policy

1. Introduction and Scope

memo69 is committed to protecting the privacy and personal data of all users who access our online gaming platform. This Privacy Policy explains how we collect, use, store, share, and protect your personal information in compliance with applicable Indonesian data protection laws and international privacy standards. By creating an account, accessing our services, or otherwise interacting with memo69, you acknowledge that you have read, understood, and consent to the data practices described in this Privacy Policy.

This Privacy Policy applies to all personal information collected through the memo69 website, mobile applications, customer support channels, and any other digital touchpoints where users interact with our brand. It covers information collected directly from users during account registration, deposit and withdrawal transactions, customer service interactions, and marketing communications. This Policy should be read in conjunction with our Terms and Conditions and Responsible Gaming Policy, which together form the complete legal framework governing your use of memo69 services.

2. Information We Collect

2.1 Information You Provide Directly

When you register for a memo69 account, we collect personal information that you voluntarily provide, including:

• Account Registration Data: Full legal name (as it appears on your Indonesian KTP - Kartu Tanda Penduduk), date of birth, gender, email address, mobile phone number, residential address, username, and password.
• Identity Verification Documents: Scanned or photographed copies of your Indonesian KTP, proof of address (utility bills, bank statements dated within 90 days), and proof of payment method ownership (bank account statements showing your name and account number).
• Financial Information: Bank account details including bank name (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, or others), account number, account holder name, and transaction history including deposits, withdrawals, wagers placed, winnings, and bonus claims.
• Communication Records: Records of all communications with memo69 customer support via live chat, email, WhatsApp, or phone, including inquiry content, complaint details, support ticket histories, and resolution outcomes.
• Responsible Gaming Preferences: Self-imposed deposit limits, loss limits, session time preferences, self-exclusion periods, and participation in responsible gaming programs or self-assessment tools.

2.2 Information Collected Automatically

When you access memo69 services, we automatically collect certain technical and usage information through cookies, log files, and similar tracking technologies:

• Device Information: Device type (smartphone, tablet, desktop), operating system (Android, iOS, Windows, macOS), browser type and version, screen resolution, device identifiers (IMEI, Android ID, IDFA), and mobile network information.
• Connection Data: IP address, internet service provider, geographical location (city and region level, not precise GPS coordinates), connection timestamps, and session duration.
• Usage Information: Pages visited, games played, bets placed (including bet amounts, odds, outcomes), time spent on specific pages or games, click patterns, navigation paths through our platform, features used, and performance metrics.
• Cookie Data: Authentication cookies to maintain login sessions, preference cookies to remember your language and display settings, analytical cookies to understand user behavior patterns, and security cookies to detect fraud and unauthorized access attempts.

2.3 Information from Third Parties

memo69 may receive information about you from third-party sources including payment processors confirming your bank account ownership, identity verification services validating your KTP authenticity, fraud detection agencies flagging suspicious activity patterns, and marketing partners (only if you have consented to data sharing with those partners). We integrate this third-party information with data we collect directly to enhance security, prevent fraud, and improve service quality.

3. How We Use Your Information

memo69 processes your personal information for specific, legitimate purposes that enable us to provide gaming services, maintain platform security, comply with legal obligations, and enhance user experience. We use your data for the following purposes:

3.1 Service Provision and Account Management

• Creating and maintaining your user account
• Processing deposits and withdrawals via Indonesian banks (BCA, BRI, BNI, Mandiri, and others)
• Enabling sports betting, casino games, slots, and other gaming activities
• Calculating and crediting winnings, bonuses, and promotional rewards
• Providing customer support and responding to inquiries
• Sending transactional notifications (deposit confirmations, withdrawal approvals, bonus activations)

3.2 Security, Fraud Prevention, and Compliance

• Verifying your identity and age to ensure compliance with 21+ age restrictions
• Detecting and preventing fraud, money laundering, collusion, and other prohibited activities
• Monitoring betting patterns to identify problem gambling behaviors and enforce responsible gaming policies
• Complying with anti-money laundering (AML) and know-your-customer (KYC) regulations
• Investigating disputes, Terms violations, and suspicious account activity
• Protecting against unauthorized access, hacking attempts, and cyber attacks

3.3 Platform Improvement and Analytics

• Analyzing user behavior to improve platform performance and user interface design
• Optimizing game loading times for Indonesian internet infrastructure
• Testing new features and services before wider deployment
• Understanding which games, sports, and promotions are most popular among Indonesian users
• Enhancing mobile optimization for Android and iOS devices

3.4 Marketing and Communications (With Consent)

With your explicit consent, we may use your email address, phone number, and account activity data to send you promotional offers, bonus announcements, new game releases, and personalized recommendations. You can opt out of marketing communications at any time by clicking the unsubscribe link in emails, adjusting your account preferences, or contacting support. Note that opting out of marketing does not affect transactional emails which are necessary for account operation.

4. How We Share Your Information

memo69 does not sell your personal information to third parties. However, we may share your data with specific categories of third-party service providers and partners under strict confidentiality agreements to facilitate our operations:

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon) and payment gateway providers receive your bank account information and transaction details to process deposits and withdrawals. These processors are bound by banking secrecy laws and contractual obligations to protect your financial data.
• Game Providers: Third-party game studios providing slots, live casino, and other games may receive limited information about your gameplay sessions (username, bet amounts, game outcomes) to facilitate gaming services. Providers do not receive your identity documents or bank details.
• Identity Verification Services: Specialized KYC providers receive your KTP scans and personal details to verify your identity and age. These services use automated and manual checks to detect fraudulent documents and underage gambling attempts.
• Cloud Hosting and IT Infrastructure: Our platform is hosted on secure cloud servers which process and store your data. Hosting providers are contractually obligated to maintain strict security standards including encryption, access controls, and regular security audits.
• Customer Support Tools: Live chat and ticketing systems used by our support team may access your communication history and account details to provide effective assistance. Support staff are trained in data protection and bound by confidentiality agreements.
• Analytics Providers: We use analytics services to understand user behavior patterns. These providers receive anonymized or pseudonymized data that cannot directly identify individuals.
• Legal and Regulatory Authorities: We may disclose your information to Indonesian law enforcement, tax authorities, or regulatory bodies when legally required to comply with court orders, subpoenas, anti-money laundering investigations, or other legal processes.

5. Data Security Measures

memo69 implements comprehensive technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. Our security framework includes multiple layers of protection:

• Encryption: All data transmitted between your device and our servers is protected by 256-bit SSL (Secure Socket Layer) encryption, the same standard used by major Indonesian banks. Sensitive data stored in our databases, including identity documents and financial records, is encrypted at rest using AES-256 encryption.
• Access Controls: Only authorized personnel with legitimate business needs can access user data. Access is granted based on role-based permissions, and all data access is logged and monitored. Employees undergo background checks and sign confidentiality agreements before gaining system access.
• Regular Security Audits: Our systems undergo regular vulnerability assessments and penetration testing by independent security firms to identify and address potential weaknesses before they can be exploited.
• Fraud Detection Systems: We employ advanced fraud detection algorithms that monitor betting patterns, account behaviors, and transaction anomalies in real-time to identify suspicious activity and prevent unauthorized access.
• Secure Password Requirements: User passwords must meet minimum complexity requirements (8+ characters, mixed case, numbers, special characters) and are stored using industry-standard hashing algorithms that make them unreadable even if databases are compromised.
• Firewall Protection: Multiple layers of firewalls protect our infrastructure from external threats including DDoS attacks, SQL injection attempts, and cross-site scripting vulnerabilities.

While memo69 implements robust security measures, no system is entirely immune to sophisticated attacks. You are responsible for maintaining the confidentiality of your account credentials. Never share your password with anyone, and immediately notify us if you suspect unauthorized account access. memo69 cannot be held liable for security breaches resulting from your failure to protect your login credentials.

6. Data Retention and Deletion

memo69 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. Specific retention periods vary based on data type:

• Active Account Data: Account information, transaction history, and gameplay records are retained for the duration of your account's active status plus six months after account closure to address potential disputes or fraud investigations.
• Identity Verification Documents: KTP scans and proof-of-address documents are retained for five years after account closure to comply with Indonesian anti-money laundering regulations and KYC record-keeping requirements.
• Financial Transaction Records: Deposit, withdrawal, and wagering records are retained for seven years to comply with Indonesian tax laws and financial record-keeping obligations.
• Communication Records: Customer support communications are retained for three years to facilitate service improvement and address recurring issues.
• Marketing Consent Records: Records of your marketing preferences and consent timestamps are retained for five years to demonstrate compliance with consent requirements.

You may request deletion of your personal data by contacting our Data Protection Officer. However, we may refuse deletion requests if retention is required for legal compliance, dispute resolution, or fraud prevention purposes. Upon account closure, we anonymize or pseudonymize data where possible so it can no longer identify you while still supporting aggregate analytics and business intelligence.

7. Your Privacy Rights

As a memo69 user, you have specific rights regarding your personal data under Indonesian privacy laws. These rights include:

• Right to Access: You may request a copy of all personal information we hold about you. We will provide this information in a commonly used electronic format within 30 days of your request.
• Right to Rectification: You may correct inaccurate or incomplete personal information through your account settings or by contacting customer support. We will update your information within 14 business days.
• Right to Deletion: You may request deletion of your personal data, subject to legal retention requirements. We will process deletion requests within 30 days, though some data may be retained as outlined in Section 6.
• Right to Restriction of Processing: You may request that we limit how we process your data in certain circumstances, such as while we verify data accuracy or investigate a complaint.
• Right to Data Portability: You may request a machine-readable copy of your data to transfer to another service provider.
• Right to Object: You may object to processing of your data for marketing purposes or when processing is based on legitimate interests rather than consent.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

To exercise any of these rights, contact our Data Protection Officer at [email protected] (please copy this email address rather than clicking). We may require proof of identity before processing your request to ensure data security. We aim to respond to all privacy requests within 30 days. If we cannot fulfill your request, we will explain why.

8. Cookies and Tracking Technologies

memo69 uses cookies and similar tracking technologies to enhance user experience, maintain session security, analyze platform usage, and deliver personalized content. Cookies are small text files stored on your device that allow us to recognize you across visits and remember your preferences.

Types of Cookies We Use:

• Essential Cookies: Required for basic platform functionality including login authentication, shopping cart functionality, and security features. These cannot be disabled.
• Performance Cookies: Help us understand how users interact with our platform by collecting anonymous usage statistics. These cookies inform decisions about platform improvements and optimization.
• Functionality Cookies: Remember your preferences such as language selection, display settings, and game favorites to provide a personalized experience.
• Targeting/Advertising Cookies: Used to deliver relevant promotional offers based on your gaming interests and activity patterns. You can opt out of these via browser settings.

You can control cookies through your browser settings. Most browsers allow you to refuse all cookies or accept only specific types. However, disabling essential cookies will impair platform functionality and prevent you from accessing certain features. Disabling analytics cookies helps protect your privacy but limits our ability to improve services based on usage patterns.

9. Children's Privacy

memo69 services are strictly intended for adults aged 21 and older. We do not knowingly collect personal information from individuals under 21 years of age. Our age verification processes, including mandatory KTP validation, are designed to prevent underage access. If we discover that we have inadvertently collected data from someone under 21, we will immediately delete that information and permanently close the associated account without refund of any balances.

Parents or guardians who believe their child has provided personal information to memo69 should immediately contact our Data Protection Officer at [email protected] (please copy and paste this address). We take underage gambling prevention seriously and cooperate with parents to remove any underage accounts discovered. Users who provide false age information face permanent account closure and potential legal consequences.

10. Changes to This Privacy Policy

memo69 reserves the right to modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. Material changes will be communicated via email to your registered email address and through prominent notice on our platform at least 30 days before taking effect. The "Last Updated" date at the top of this document indicates the most recent revision.

Your continued use of memo69 services after notification of Privacy Policy changes constitutes acceptance of the revised Policy. If you do not agree with the updated terms, you must cease using our services and may request account closure and data deletion subject to legal retention requirements. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

11. Contact Information and Data Protection Officer

For questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact memo69's Data Protection Officer:

• Email: [email protected] (please copy and paste this address into your email client)
• Subject Line: Please use "Privacy Inquiry" or "Data Protection Request" for faster processing
• Response Time: We aim to respond to all privacy-related inquiries within 30 days
• Required Information: Include your memo69 username and registered email address to verify your identity

If you believe memo69 has not adequately addressed your privacy concerns, you may file a complaint with the relevant Indonesian data protection authority. However, we encourage you to contact us first so we can attempt to resolve your concerns directly.