Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal data collected by koi33 through our website, mobile applications, and related services (collectively, "the Platform"). It covers data collected from residents of Indonesia and other jurisdictions where we operate.

koi33 operates as an international online gaming platform and is committed to complying with applicable data protection laws and regulations. Where local laws impose stricter requirements than those set forth in this policy, we will adhere to those local standards.

This policy should be read in conjunction with our Terms & Conditions, which govern your use of koi33 services. By creating an account or using our Platform, you acknowledge that you have read and understood this Privacy Policy.

2. Information We Collect

2.1 Personal Information You Provide

When you register an account with koi33, we collect the following personal information directly from you:

• Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification number (KTP number for Indonesian residents)
• Contact Information: Email address, mobile phone number, residential address, and postal code
• Financial Information: Bank account details (account number, bank name, account holder name), e-wallet information (OVO, DANA, GoPay account details), payment card information, and transaction history
• Account Credentials: Username, password (stored in encrypted form), and security questions/answers
• Verification Documents: Copies of government-issued ID (KTP, passport), proof of address documents (utility bills, bank statements), and selfie photographs for identity verification
• Communication Records: Content of your communications with our customer support team via live chat, email, phone, or social media platforms

2.2 Information Collected Automatically

When you use the koi33 Platform, we automatically collect certain technical and behavioral data:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IMEI, MAC address), and mobile network information
• Connection Data: IP address, internet service provider, connection timestamps, and geographic location derived from IP address
• Usage Data: Pages visited, features used, time spent on pages, click patterns, game selections, bet amounts, win/loss records, session durations, and referral sources
• Cookies and Tracking Technologies: Session cookies, persistent cookies, web beacons, and similar tracking technologies (see Section 8 for details)

2.3 Information from Third Parties

We may receive information about you from third-party sources, including:

• Payment Processors: Transaction confirmation, payment method verification, and fraud detection data from banks, e-wallet providers, and payment gateway partners
• Identity Verification Services: Age verification results, identity authentication confirmations, and fraud risk assessments from third-party KYC providers
• Marketing Partners: Referral source data and campaign performance metrics from affiliate marketing partners (where applicable)
• Game Providers: Game session data, RTP calculations, and bonus usage from third-party software providers like Pragmatic Play, Evolution Gaming, and Microgaming

3. How We Use Your Information

koi33 uses your personal data for the following purposes, each of which is necessary for the performance of our contract with you, compliance with legal obligations, or pursuit of our legitimate business interests:

3.1 Account Management and Service Delivery

• Creating and maintaining your gaming account
• Processing deposits, withdrawals, and other financial transactions
• Verifying your identity and age to comply with legal requirements (players must be 21+)
• Providing customer support and responding to your inquiries
• Managing bonuses, promotions, and loyalty programs
• Enabling gameplay across our casino, sports betting, and lottery products

3.2 Security, Fraud Prevention, and Legal Compliance

• Detecting and preventing fraudulent activity, money laundering, and other illegal conduct
• Monitoring for account takeover attempts, payment fraud, and bonus abuse
• Complying with anti-money laundering (AML) and know-your-customer (KYC) regulations
• Enforcing our Terms & Conditions and investigating breaches
• Responding to legal requests from government authorities, law enforcement, or regulatory bodies
• Maintaining records as required by applicable gaming regulations

3.3 Marketing and Communications

• Sending promotional offers, bonus announcements, and new game notifications via email, SMS, or push notifications (only with your consent)
• Personalizing marketing content based on your gaming preferences and activity history
• Conducting surveys and collecting feedback to improve our services
• Sending important account-related notifications (transaction confirmations, security alerts, policy updates)

3.4 Platform Improvement and Analytics

• Analyzing usage patterns to understand which games and features are most popular
• Conducting A/B testing to optimize user experience and interface design
• Identifying technical issues, bugs, and performance bottlenecks
• Developing new features, games, and services based on player behavior
• Generating aggregated, anonymized reports for business intelligence purposes

3.5 Responsible Gaming and Player Protection

• Monitoring for signs of problem gambling behavior
• Enforcing self-exclusion requests and deposit limits
• Providing access to responsible gaming tools and support resources
• Intervening proactively when we detect potentially harmful gambling patterns

4. Legal Basis for Processing (GDPR and Indonesian Data Protection)

For players in jurisdictions with comprehensive data protection laws, we process your personal data under the following legal bases:

• Contractual Necessity: Processing required to provide gaming services as per our Terms & Conditions (account management, payments, customer support)
• Legal Obligation: Processing required to comply with AML/KYC regulations, age verification laws, tax reporting, and other legal requirements
• Legitimate Interests: Processing necessary for fraud prevention, security monitoring, platform improvement, and business analytics (balanced against your privacy rights)
• Consent: Marketing communications, personalized advertising, and optional data uses (you may withdraw consent at any time)

5. Data Sharing and Disclosure

koi33 does not sell your personal data to third parties. We share your information only in the following limited circumstances:

5.1 Service Providers and Business Partners

We engage trusted third-party service providers to support our operations. These partners process data on our behalf under strict confidentiality agreements:

Service Provider Category	Data Shared	Purpose
Payment Processors	Name, bank account details, transaction amounts	Processing deposits and withdrawals via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay
Identity Verification Services	KTP number, date of birth, ID document scans	Age verification and anti-fraud checks
Game Software Providers	Account ID, gameplay data, bet history	Delivering casino games, sports betting, and live dealer experiences
Customer Support Platforms	Name, email, chat transcripts	Managing support tickets and live chat communications
Cloud Hosting Providers	All account and transaction data	Securely storing encrypted data on international servers
Marketing and Analytics Tools	Email address, usage patterns (anonymized where possible)	Sending promotional emails and analyzing platform performance

5.2 Legal and Regulatory Disclosures

We may disclose your personal data when required by law or to protect our legal rights:

• In response to valid legal requests from law enforcement, courts, or regulatory authorities
• To comply with anti-money laundering investigations or tax reporting obligations
• To enforce our Terms & Conditions or investigate suspected fraud, cheating, or Terms violations
• To protect the safety and security of koi33, our players, or the public
• In connection with a business transaction such as a merger, acquisition, or sale of assets (your data would be transferred to the successor entity)

5.3 International Data Transfers

koi33 operates internationally, and your data may be transferred to and processed in countries outside Indonesia, including jurisdictions that may have different data protection standards. We ensure appropriate safeguards are in place through:

• Standard contractual clauses approved by data protection authorities
• Hosting with cloud providers certified under international security standards (ISO 27001, SOC 2)
• Encryption of data in transit and at rest
• Regular security audits and compliance reviews

6. Data Security Measures

koi33 employs industry-leading security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction:

• Encryption: All data transmitted between your device and our servers is encrypted using TLS 1.3 (Transport Layer Security). Sensitive data stored in our databases (passwords, financial information) is encrypted using AES-256 encryption.
• Access Controls: Personal data is accessible only to authorized koi33 employees and contractors who require it to perform their duties. Access is logged and monitored.
• Two-Factor Authentication: Account access requires both password and mobile verification code for enhanced security.
• Firewall and Intrusion Detection: Our servers are protected by enterprise-grade firewalls and real-time intrusion detection systems.
• Regular Security Audits: We conduct quarterly penetration testing and annual third-party security audits to identify and address vulnerabilities.
• Employee Training: All staff members undergo data protection and security awareness training upon hiring and annually thereafter.

While we implement robust security measures, no system is completely immune to attacks. In the unlikely event of a data breach affecting your information, we will notify you promptly in accordance with applicable law.

7. Data Retention

koi33 retains your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy and to comply with legal obligations:

• Active Accounts: Personal and transaction data is retained while your account remains active and for a period after closure to comply with regulatory record-keeping requirements.
• Closed Accounts: After you close your account, we retain core identity information (name, KTP number, date of birth) and transaction records for 7 years to comply with anti-money laundering and tax regulations.
• Marketing Data: If you unsubscribe from marketing communications, we will stop sending promotional content but retain your email address in a suppression list to honor your opt-out preference.
• Legal Holds: If your data is subject to a legal investigation, regulatory inquiry, or pending dispute, we will retain relevant records until the matter is resolved.

After the retention period expires, personal data is securely deleted or anonymized so it can no longer be associated with you.

8. Cookies and Tracking Technologies

koi33 uses cookies and similar technologies to enhance your experience, analyze usage patterns, and deliver personalized content. Cookies are small text files stored on your device when you visit our Platform.

8.1 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function (login sessions, security tokens, shopping cart). These cannot be disabled.
• Performance Cookies: Collect anonymous data on page load times, error rates, and feature usage to help us optimize performance.
• Functional Cookies: Remember your preferences (language, currency, game favorites) for a personalized experience.
• Marketing Cookies: Track your interaction with promotional content to measure campaign effectiveness and deliver relevant ads.

You can manage cookie preferences through your browser settings. Note that disabling essential cookies may impair Platform functionality.

9. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you.
• Correction: Update or correct inaccurate information in your account settings or by contacting support.
• Deletion: Request deletion of your data (subject to legal retention requirements).
• Portability: Receive your data in a structured, machine-readable format.
• Objection: Object to processing based on legitimate interests or direct marketing.
• Restriction: Request temporary restriction of processing under certain circumstances.
• Withdraw Consent: Revoke consent for marketing communications or optional data uses at any time.

To exercise these rights, contact our Data Protection Officer at [email protected]. We will respond within 30 days.

10. Children's Privacy

koi33 services are strictly prohibited for individuals under 21 years of age. We do not knowingly collect personal data from minors. If we discover that a user is underage, we will immediately close their account and delete associated data. Parents or guardians who believe their child has provided information to koi33 should contact us immediately.

11. Changes to This Privacy Policy

koi33 reserves the right to update this Privacy Policy to reflect changes in our practices, legal requirements, or Platform features. We will notify you of material changes by posting the updated policy on our website and sending email notification to registered users. Your continued use of koi33 services after changes take effect constitutes acceptance of the updated policy.

12. Contact Information

For questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact:

• Email: [email protected]
• Subject Line: "Privacy Inquiry" or "Data Protection Request"
• Response Time: We aim to respond to all privacy-related inquiries within 7 business days