uno189 Privacy Policy

1 Definitions

The following defined terms are used throughout this Policy:

• "Personal Data" — Any information that identifies or could reasonably be used to identify a natural person, directly or indirectly. This includes your name, national identity number, email address, IP address, device identifiers, and financial account details.
• "Processing" — Any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" — The entity that determines the purposes and means of processing Personal Data. For this platform, the Data Controller is uno189.
• "Data Processor" — A third party that processes Personal Data on behalf of uno189 under a binding data-processing agreement.
• "Player" / "User" / "you" — Any natural person who has registered, or is in the process of registering, an Account on the uno189 platform.
• "Platform" — The uno189 website at https://uno189.app and all associated pages and services.
• "KYC" — Know Your Customer identity verification procedures required under our licensing obligations and anti-money-laundering commitments.
• "Cookies" — Small text files placed on your device by the Platform to recognize your browser, store session state, and collect usage analytics.

2 Data Controller

uno189 acts as the Data Controller for all Personal Data collected through the Platform. All data-protection inquiries, subject-access requests, and complaints should be directed to our designated Privacy Team using the contact details provided in Section 15 of this Policy.

Where uno189 engages third-party service providers to process data on its behalf — such as payment processors, game providers, analytics platforms, and fraud-detection services — those providers act as Data Processors under written agreements that impose obligations equivalent to those described in this Policy.

3 Data We Collect

uno189 collects the minimum Personal Data necessary to deliver a safe, compliant, and high-quality betting and casino experience to Indonesian Players. The categories of data we collect are set out below:

3.1 Registration & Account Data

• Full legal name (as it appears on government-issued identification)
• Date of birth (to verify the 21+ age requirement)
• Indonesian residential address
• Email address
• Mobile phone number (used for account notifications and, optionally, SMS two-factor authentication)
• Username and encrypted password hash
• Preferred currency (IDR)

3.2 Identity Verification (KYC) Data

• Copy of National Identity Card (KTP), Passport, or Driving License (SIM)
• Proof of Indonesian residential address (utility bill, bank statement, or official correspondence)
• Photo or screenshot of the bank account or e-wallet (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata, OCBC NISP, OVO, DANA, GoPay, ShopeePay, or LinkAja) registered in your name
• Source-of-funds documentation where transaction thresholds trigger enhanced due diligence

3.3 Financial Transaction Data

• Deposit and withdrawal amounts, dates, and transaction reference numbers
• Bank account numbers and e-wallet account identifiers used for transactions
• Bonus claims, wagering activity, and account balance history

3.4 Technical & Device Data

• IP address and derived geolocation (country and city level)
• Browser type, version, and language settings
• Operating system and device type (desktop, mobile, tablet)
• Device fingerprint identifiers used to detect multi-accounting
• Session timestamps, login history, and logout events

3.5 Behavioral & Usage Data

• Pages visited, time spent on each page, and click-path data
• Games played, bet types (sportsbook, live casino, slots), wager amounts, and game session durations
• Bonus uptake, promotional interactions, and responsible gaming tool usage
• Customer support inquiry history, chat transcripts, and email correspondence

3.6 Communications Data

• Email communications sent to or received from [email protected]
• Live chat transcripts with our 24/7 support team
• WhatsApp messages sent to +62 811 0001 8900 for support purposes
• Survey responses and feedback submissions

4 How We Collect Your Data

uno189 collects Personal Data through the following channels:

• Directly from you — when you register an Account, complete the KYC process, make a deposit or withdrawal, contact customer support, respond to a promotion, or interact with any Platform feature that requires input.
• Automatically — through cookies, pixel tags, server logs, and analytics SDKs embedded in the Platform that record technical and behavioral data each time you access the site.
• From third-party game providers — providers such as Evolution Gaming, Pragmatic Play, Pocket Games Soft, NetEnt, and Spribe may share session outcome data and technical event logs with uno189 for dispute resolution, fraud detection, and responsible gaming monitoring.
• From payment service providers — Indonesian bank systems (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata, OCBC NISP) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) provide transaction confirmation data to enable deposit crediting and withdrawal processing.
• From fraud and compliance databases — we may cross-reference registration data against publicly available sanctions lists, politically exposed persons (PEP) registers, and third-party fraud detection services as part of our KYC and anti-money-laundering obligations.

5 Legal Basis for Processing

uno189 processes your Personal Data only where a valid legal basis exists. The applicable legal bases for each processing activity are summarized below:

6 How We Use Your Data

uno189 uses the Personal Data collected for the following specific purposes:

• Account Services: Creating and maintaining your Account, processing logins, and enabling the full range of Platform features including sportsbook wagering, live casino tables, and slot sessions.
• Identity & Age Verification: Confirming that you are at least 21 years of age and a resident of Indonesia, as required by our responsible gaming policy and licensing conditions.
• Transaction Processing: Crediting deposits made via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja; processing withdrawal requests to your verified payment method; and maintaining an accurate audit trail of all IDR transactions on your Account.
• Bonus & Promotions Administration: Determining your eligibility for welcome bonuses, reload promotions, cashback offers, and seasonal incentives tied to events such as Idul Fitri, Ramadhan, and Indonesian Independence Day (17 August); tracking wagering requirement progress; and distributing bonus credits.
• Fraud Prevention & Platform Security: Detecting and investigating unauthorized Account access, multi-accounting, bonus abuse, money laundering, and other Restricted Activities defined in the Terms & Conditions.
• Responsible Gaming: Monitoring Player behavior for indicators of problem gambling (such as rapid deposit escalation, loss-chasing patterns, or extended continuous sessions); enforcing self-exclusion periods; and respecting deposit limits and cooling-off requests.
• Customer Support: Responding to inquiries submitted via live chat, email, and WhatsApp; resolving disputes regarding game outcomes, transaction discrepancies, or bonus eligibility; and maintaining support-interaction records for quality assurance.
• Legal & Regulatory Compliance: Meeting our obligations under applicable anti-money-laundering regulations, international licensing conditions, and any lawful requests from competent regulatory authorities.
• Platform Improvement: Analyzing aggregated and anonymized usage data to improve site performance, game lobby design, payment flow, and mobile experience — particularly for Players accessing the Platform from Jakarta, Surabaya, Bandung, Bali, Medan, and other Indonesian cities.
• Marketing Communications (with consent): Sending promotional emails, SMS alerts, and WhatsApp notifications about bonuses, new game launches, sporting events, and seasonal offers. You may withdraw consent at any time via Account Settings or by contacting [email protected].

7 Data Sharing & Third Parties

uno189 shares Personal Data only in the limited circumstances described below, and only to the extent necessary for the stated purpose:

7.1 Game Providers

To provide live casino, slot, and sportsbook services, uno189 shares relevant Player identifiers (such as anonymized session tokens) with certified providers including Evolution Gaming, Pragmatic Play, Pocket Games Soft, NetEnt, Microgaming, Spribe, and Hacksaw Gaming. These providers operate under their own privacy frameworks and are contractually prohibited from using shared data for any purpose other than delivering the game service.

7.2 Payment Service Providers

Transaction data — including bank account numbers, e-wallet identifiers, and IDR amounts — is shared with Indonesian payment networks and processors (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata, OCBC NISP, OVO, DANA, GoPay, ShopeePay, LinkAja) solely to initiate, confirm, and record financial transactions.

7.3 KYC & Fraud Services

Identity verification data may be processed by accredited third-party KYC platforms and fraud-detection engines that operate as Data Processors under binding agreements with uno189. These services analyze document authenticity, cross-check sanctions and PEP lists, and detect device-level fraud signals.

7.4 Analytics & Technology Providers

Aggregated, anonymized, or pseudonymized technical and behavioral data may be processed by analytics and cloud infrastructure providers to support platform performance monitoring, uptime management, and user-experience optimization. No directly identifiable Personal Data is shared with analytics providers beyond what is necessary for session-level analysis.

7.5 Legal & Regulatory Disclosure

uno189 may disclose Personal Data to law enforcement agencies, regulatory bodies, or courts where required to do so by law, regulation, court order, or the instructions of our licensing authority. We will, where legally permitted, notify affected Players of such disclosures in advance.

7.6 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of assets involving uno189, Player Personal Data may be transferred to the acquiring or successor entity. Players will be notified of any such transfer and their rights in respect of it prior to the transfer taking effect.

8 Cookies & Tracking Technologies

uno189 uses cookies and similar tracking technologies to operate and improve the Platform. The categories of cookies in use are described below:

You may manage or delete cookies through your browser settings at any time. Disabling strictly necessary cookies will prevent you from logging in or using core Platform features. Disabling analytics or functional cookies will not affect your ability to place bets or make transactions, but may degrade your personalized experience.

9 Data Retention

uno189 retains Personal Data only for as long as is necessary to fulfill the purposes described in this Policy, unless a longer retention period is required by law or our licensing obligations. The key retention periods applicable to Player data are:

• Active Account Data: Retained for the full duration of your Account's active status, plus a minimum of 5 years following Account closure — in line with standard anti-money-laundering record-keeping requirements.
• KYC Documents: Retained for a minimum of 5 years from the date of Account closure or the date of the last relevant transaction, whichever is later.
• Financial Transaction Records: Retained for a minimum of 5 years to meet audit and regulatory compliance obligations.
• Customer Support Records: Retained for 3 years from the date of the most recent interaction, to support dispute resolution and service quality review.
• Marketing Preferences & Consent Records: Retained for the duration of Account activity plus 2 years, to demonstrate compliance with consent obligations.
• Technical & Session Logs: Retained for up to 13 months, after which they are either deleted or irreversibly anonymized for aggregate analytics purposes.

When a retention period expires and no overriding legal obligation exists, Personal Data is securely deleted or anonymized in accordance with uno189's internal data destruction procedures.

10 Data Security

uno189 implements a comprehensive suite of technical and organizational security measures designed to protect your Personal Data against unauthorized access, accidental loss, alteration, or disclosure:

• Encryption in Transit: All data exchanged between your browser and the Platform is encrypted using TLS 1.3, the current industry standard for secure web communications.
• Encryption at Rest: Sensitive data fields — including passwords (stored as bcrypt hashes), payment identifiers, and KYC document files — are encrypted at rest using AES-256 encryption.
• Access Controls: Access to Personal Data within our systems is strictly limited to personnel who require it to perform their job functions. All internal access is logged, reviewed, and subject to least-privilege principles.
• Two-Factor Authentication (2FA): Players are strongly encouraged to enable 2FA on their Account. All uno189 staff with access to Player data systems are required to use 2FA.
• Vulnerability Management: The Platform undergoes regular security assessments, penetration testing, and code reviews by qualified information security professionals.
• Incident Response: In the event of a confirmed data breach that poses a risk to Player rights, uno189 will notify affected Players and the relevant supervisory authority within the timeframe required by applicable law.

11 Your Privacy Rights

Depending on applicable data protection law, you may hold some or all of the following rights in respect of your Personal Data held by uno189. To exercise any of these rights, contact our Privacy Team at [email protected] with the subject line "Privacy Rights Request – [Your Username]".

• Right of Access: You may request a copy of all Personal Data uno189 holds about you, together with information about how it is processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete Personal Data. You can update most Account details directly via Account Settings; for KYC-level corrections, contact support.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your Personal Data where it is no longer needed for the purpose for which it was collected, where you have withdrawn consent, or where processing was unlawful. This right is subject to override by legal retention obligations (e.g., AML record-keeping).
• Right to Restriction of Processing: You may request that we temporarily restrict processing of your data while a dispute about its accuracy or lawfulness is being resolved.
• Right to Data Portability: You may request a machine-readable export of Personal Data you provided directly to uno189, where processing is based on contract or consent.
• Right to Object: You may object to processing based on legitimate interest (including profiling for marketing purposes) at any time. We will cease such processing unless we can demonstrate compelling legitimate grounds.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw consent at any time via Account Settings or by emailing [email protected]. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

We will respond to all verified rights requests within 30 calendar days. Where requests are complex or numerous, we may extend this period by up to 60 additional days, in which case we will notify you within the initial 30-day window.

12 Minors & Age Verification

The uno189 Platform is strictly for adults aged 21 and over. We do not knowingly collect Personal Data from individuals under the age of 21. Age verification is a mandatory component of the KYC process; registration cannot be completed without confirming that the applicant meets the minimum age requirement.

If uno189 discovers or reasonably suspects that an Account holder is under 21 years of age, all funds associated with that Account will be frozen, all gameplay voided, and the Account permanently closed. Any deposits made by an underage Player will be returned to the originating payment method after internal review. We will delete any Personal Data collected from underage individuals as promptly as the investigation allows.

If you believe an underage individual has registered on the Platform, please report this immediately to [email protected] with the subject line "Underage Player Report".

13 International Data Transfers

uno189 operates as an international platform, and some of the third-party Data Processors engaged by uno189 — including game providers, cloud infrastructure providers, and analytics platforms — may process data on servers located outside of Indonesia. Where Personal Data is transferred to a jurisdiction that does not offer a level of data protection equivalent to that applicable in Indonesia, uno189 ensures that appropriate safeguards are in place, which may include:

• Contractual clauses that impose data protection obligations on the recipient equivalent to those described in this Policy.
• Requiring the recipient to implement technical security standards consistent with those applied by uno189.
• Limiting the scope of data transferred to the minimum necessary for the specific processing purpose.

For specific information about the safeguards applicable to any international transfer of your Personal Data, contact our Privacy Team at [email protected].

14 Changes to This Policy

uno189 reserves the right to update this Privacy Policy at any time to reflect changes in our data-processing practices, legal obligations, or Platform features. When changes are material, we will notify you by email to your registered address and/or via a prominent in-platform notification at least 7 days before the revised Policy takes effect.

The "Effective Date" displayed at the top of this document reflects the date of the most recent version. We encourage you to review this Policy periodically. Your continued use of the Platform following the effective date of any update constitutes your acknowledgment of the revised Policy.

15 Contact & Complaints

For all privacy-related inquiries, subject-access requests, complaints, or reports of potential data breaches, please contact the uno189 Privacy Team using the following channels:

• Email: [email protected] — use the subject line "Privacy Rights Request", "Data Breach Report", or "Privacy Complaint" as applicable.
• WhatsApp: +62 811 0001 8900 — available for real-time support queries (24/7).
• Live Chat: Available 24/7 via the Platform interface for immediate assistance.

We aim to acknowledge all privacy-related emails within 2 business days (08:00–24:00 WIB) and to resolve complaints within 30 calendar days. If you are not satisfied with our response to a privacy complaint, you retain the right to escalate the matter to the relevant supervisory authority in your jurisdiction.