Privacy Policy — indo911

This Privacy Policy (the "Policy") sets out the manner in which indo911 (referred to herein as "indo911", "the Platform", "we", "us", or "our") collects, processes, stores, discloses, and protects personal data relating to individuals ("Players", "Users", or "you") who access or use the indo911 online gaming platform at https://indo911.cam.

indo911 is committed to safeguarding the privacy of all Players and to processing personal data in a manner that is lawful, fair, and transparent. This Policy is designed to inform you clearly about your privacy rights and how the law protects you as a user of our platform.

This Policy applies to all personal data collected through: your use of the indo911 website and any mobile-optimised version thereof; your account registration and subsequent account management activities; your deposits, withdrawals, and gaming transactions; your interactions with our customer support team; and your participation in promotional programmes and loyalty schemes.

This Privacy Policy should be read in conjunction with indo911's Terms & Conditions, which govern your use of the Platform and form part of the overall agreement between you and indo911.

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below:

indo911 collects personal data across several categories, depending on how you interact with the Platform. The categories of data we collect are set out in the table below:

indo911 does not collect or process special categories of personal data (such as racial origin, health information, or biometric data) except where strictly required for age verification or identity confirmation as part of a mandated KYC process.

indo911 collects personal data through the following mechanisms:

• Direct Collection: Data you provide to us directly during account registration, KYC submission, deposit and withdrawal requests, promotional opt-ins, and communications with our customer support team.
• Automated Technical Collection: Data collected automatically when you visit the Platform, including IP address, device identifiers, browser information, session logs, and cookie data, via our web servers and analytics infrastructure.
• Payment Processors: Transaction confirmation data, reference numbers, and partial payment method identifiers received from our integrated Malaysian payment partners (Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, Maybank2u, CIMB Clicks, Public Bank Online, Hong Leong Connect) when you make a deposit or request a withdrawal.
• KYC Verification Partners: Identity verification results and document authenticity assessments provided by our third-party KYC service providers when you submit your verification documents.
• Third-Party Analytics: Aggregated, anonymised usage data from analytics tools used to understand platform performance and improve user experience. This data does not identify individual users.

indo911 processes personal data only for specific, legitimate purposes. The table below sets out the primary purposes for which we process each category of data:

indo911 will not use your personal data for any purpose that is incompatible with the purposes listed above, unless we obtain your separate consent or are required to do so by law.

indo911 processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing that is necessary for the performance of the contract between you and indo911 — specifically, operating your account, processing transactions, providing access to games and the sportsbook, and fulfilling our obligations under the Terms & Conditions.
• Legal Obligation: Processing required to comply with applicable legal and regulatory obligations, including Anti-Money Laundering (AML) requirements, Know Your Customer (KYC) obligations, age verification requirements, and data retention mandates imposed by applicable law.
• Legitimate Interests: Processing carried out in pursuit of indo911's legitimate business interests, including fraud detection and prevention, platform security monitoring, responsible gambling risk assessment, and internal analytics — provided these interests are not overridden by your fundamental rights and freedoms.
• Consent: Where required, indo911 will seek your explicit consent before processing your data for specific purposes — in particular, the sending of direct marketing communications. You may withdraw consent at any time by contacting our support team or adjusting your account communication preferences.

indo911 does not sell, rent, or trade your personal data to any third party for their own commercial purposes. We may share your personal data with third parties only in the circumstances described below:

• Payment Service Providers: We share necessary transaction data with our integrated Malaysian payment partners — including Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX providers, Maybank, CIMB, Public Bank, and Hong Leong — solely for the purpose of processing your deposits and withdrawals.
• KYC & Identity Verification Providers: We share identity documents and personal data with our contracted third-party KYC verification service providers for the purpose of verifying your identity and age in compliance with our regulatory obligations.
• Game Studio Partners: Certain gameplay data (such as Player ID, bet amounts, and game results) is shared with our licensed game studio partners to facilitate the provision of their game content on the Platform. These partners are contractually restricted from using this data for any purpose other than game service delivery.
• Cloud Infrastructure Providers: Our Platform is hosted on cloud infrastructure provided by third-party server and storage providers. These providers process data on our behalf under strict data processing agreements and have no independent right to access or use your data.
• Legal and Regulatory Authorities: We may be required to disclose your personal data to law enforcement agencies, regulatory bodies, or courts of competent jurisdiction in connection with legal proceedings, investigations, or in response to lawful requests. indo911 will disclose only the minimum data necessary to satisfy such requirements.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of our business assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and of any material change to the processing of your data that results from it.

indo911 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, unless a longer retention period is required or permitted by applicable law.

The following general retention periods apply to the principal categories of personal data held by indo911:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be linked to an identifiable individual. Anonymised data may be retained indefinitely for statistical and analytical purposes.

The indo911 Platform uses cookies and similar tracking technologies to ensure the proper functioning of the website, remember your session and preferences, and support internal analytics. By continuing to use the Platform, you consent to the use of cookies as described in this clause.

The following categories of cookies are used on the indo911 Platform:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without disrupting your ability to use the Platform.
• Functional Cookies: Used to remember your preferences and settings — such as language preference and display options — to provide a more personalised experience on return visits.
• Analytics Cookies: Used to collect aggregated, anonymised data on how Players navigate and interact with the Platform. This helps us identify areas for improvement in usability and performance. Individual users are not identifiable from this data.
• Session Tracking Cookies: Used to monitor your active session on the Platform for security purposes and to enforce responsible gambling session time limits where set by the Player.

indo911 does not use third-party advertising cookies or cross-site tracking technologies that would allow your activity on our Platform to be tracked across other websites.

You may manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality and performance of the indo911 Platform.

As a Player on the indo911 Platform, you have the following rights with respect to your personal data. To exercise any of these rights, please contact our Customer Support team via live chat or email at [email protected].

• Right of Access: You have the right to request a copy of all personal data that indo911 holds about you. We will provide this information within 30 days of receiving a valid request.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected or updated. You may update certain information directly through your Account Settings page.
• Right to Erasure ("Right to be Forgotten"): You may request that we delete your personal data. Please note that this right is subject to limitations where retention is required for legal compliance, regulatory obligations, or legitimate dispute resolution purposes, as described in Clause 8.
• Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal data in certain circumstances — for example, where you contest the accuracy of the data or where you have objected to processing pending verification of our legitimate grounds.
• Right to Data Portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to the processing of your personal data where that processing is based on indo911's legitimate interests. You also have the right to object to the processing of your personal data for direct marketing purposes at any time, without needing to provide justification.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.

indo911 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS) / SSL Encryption: All data transmitted between your browser or device and our servers is encrypted using 256-bit SSL/TLS encryption, rendering it unreadable to any third party intercepting the connection.
• Access Controls: Internal access to personal data is restricted to authorised indo911 personnel with a legitimate operational need. Role-based access controls and activity logging are applied to all internal data systems.
• Encrypted Data Storage: Sensitive personal data — including KYC documents and financial identifiers — is stored in encrypted form on access-controlled servers. Encryption keys are managed separately from the data they protect.
• Two-Factor Authentication (2FA): Players are encouraged to enable 2FA on their indo911 accounts. Internal administrative systems require multi-factor authentication for all staff access.
• Security Monitoring: Indo911's infrastructure is subject to continuous security monitoring for anomalous activity, intrusion attempts, and data access irregularities.
• Third-Party Security Obligations: All data processors and third-party service providers engaged by indo911 are contractually required to implement security standards equivalent to those applied by indo911 itself.

Notwithstanding these measures, no method of electronic transmission or storage is 100% secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, indo911 will notify affected Players without undue delay through the email address registered to your account.

The indo911 Platform is strictly intended for adults. No person under the age of 21 may register an account or use any service on the indo911 Platform. This restriction applies regardless of the age of majority under any other applicable law.

indo911 does not knowingly collect or process personal data from individuals under the age of 21. If we become aware that a person under the age of 21 has provided us with personal data or has registered an account on the Platform, we will immediately suspend the account, delete all associated personal data, and — where applicable — report the matter to relevant authorities.

If you believe that a minor has accessed or registered on the indo911 Platform, please notify us immediately via our live chat support channel. We will investigate and take appropriate action without delay.

Indo911 reserves the right to update or amend this Privacy Policy at any time. When we make changes, we will update the "Last Updated" date displayed at the top of this page. Where changes are material — for example, a significant change to the purposes for which we process your data, the categories of third parties we share data with, or your rights in respect of your data — we will notify you by email to the address registered on your account, or by a prominent notice on the Platform prior to the changes taking effect.

Your continued use of the indo911 Platform following the publication of an amended Privacy Policy constitutes your acknowledgement of the changes. We encourage you to review this page periodically to remain informed about how we protect your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by indo911, please contact us through any of the following channels:

For matters specifically relating to responsible gambling, self-exclusion requests, or deposit limit adjustments, please visit our Responsible Gambling page for the relevant tools and guidance.