Privacy Policy

1. Introduction

Welcome to the Privacy Policy of 23naga (hereinafter "23naga", "we", "us", or "our"). This Privacy Policy describes how we collect, use, disclose, and protect the personal information of users (hereinafter "you", "your", or "User") who access or use our online betting and gaming platform, including all associated services, features, and applications (collectively, the "Platform" or "Services"). By registering an account, accessing the Platform, or using any of the Services, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your personal information as described in this Privacy Policy.

We are committed to protecting your privacy and ensuring that your personal data is handled in accordance with applicable data protection laws and international best practices. This Privacy Policy is designed to help you understand what information we collect, why we collect it, how we use it, and the choices you have regarding your personal data. If you do not agree with the terms of this Privacy Policy, you must immediately cease using the Platform and refrain from creating an account.

This Privacy Policy should be read in conjunction with our Terms & Conditions and our Responsible Gaming Policy, which together form the complete agreement between you and 23naga regarding your use of the Platform. We reserve the right to update or modify this Privacy Policy at any time without prior notice. Any changes will be effective immediately upon posting on this page, and the date of the most recent revision will be indicated at the bottom of this document. It is your responsibility to review this Privacy Policy periodically to stay informed of any updates.

2. Information We Collect

2.1 Personal Information Provided by You

When you register an account on 23naga, we collect personal information that you voluntarily provide to us, including but not limited to:

• Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification number (Indonesian national ID / KTP).
• Contact Information: Email address, mobile phone number, residential address, city, province, and postal code.
• Account Credentials: Username, password (stored in encrypted form), and security questions for account recovery.
• Financial Information: Bank account details (bank name, account number, account holder name), e-wallet account details (OVO, DANA, GoPay, ShopeePay, LinkAja), and transaction history (deposits, withdrawals, bets placed, winnings).
• Verification Documents: Copies of government-issued photo ID (KTP), proof of address (utility bill, bank statement), and selfie photos holding your ID for Know Your Customer (KYC) verification purposes.
• Communication Records: Any information you provide when contacting our customer support team via live chat, email, or phone, including the content of your messages and any attachments.

2.2 Information Collected Automatically

When you access or use the Platform, we automatically collect certain technical and usage information, including:

• Device Information: Device type (desktop, mobile, tablet), operating system, browser type and version, screen resolution, and device identifiers (IMEI, MAC address, advertising ID).
• Connection Information: IP address, internet service provider (ISP), geographic location (country, city, time zone), and connection timestamps.
• Usage Data: Pages visited, features accessed, games played, bets placed, time spent on the Platform, clickstream data, referral source (how you arrived at our Platform), and session activity logs.
• Cookies and Tracking Technologies: We use cookies, web beacons, pixel tags, and similar tracking technologies to collect information about your interactions with the Platform. For more information, see Section 8 (Cookies and Tracking Technologies).

2.3 Information from Third Parties

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

• Payment Processors: When you deposit or withdraw funds, we receive transaction confirmation and account verification data from your bank or e-wallet provider (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, etc.).
• Identity Verification Services: We may use third-party KYC and anti-money laundering (AML) verification services to confirm your identity and detect fraudulent activity.
• Fraud Prevention Services: We may use third-party fraud detection and prevention tools to monitor for suspicious activity, including IP geolocation services and device fingerprinting technologies.

3. How We Use Your Information

We collect and process your personal information for the following purposes:

• Account Management: To create, maintain, and manage your user account, verify your identity (KYC), and authenticate your login credentials.
• Transaction Processing: To process deposits, withdrawals, bets, and payouts, and to maintain accurate financial records for accounting and audit purposes.
• Service Delivery: To provide access to the Platform, enable gameplay on sports betting, live casino, slots, togel, sabung ayam, and other gaming products, and to deliver promotional bonuses and loyalty rewards.
• Customer Support: To respond to your inquiries, resolve disputes, troubleshoot technical issues, and provide assistance through live chat, email, and phone support.
• Fraud Prevention and Security: To detect, prevent, and investigate fraudulent activity, money laundering, underage gambling, multiple account abuse, bonus abuse, and other violations of our Terms & Conditions.
• Legal Compliance: To comply with legal obligations under anti-money laundering (AML) and counter-terrorism financing (CTF) regulations, tax reporting requirements, and licensing conditions imposed by our regulatory authority.
• Marketing and Promotions: To send you promotional offers, bonus notifications, newsletters, and updates about new games, features, and tournaments (you may opt out of marketing communications at any time).
• Platform Improvement: To analyze usage patterns, optimize website performance, enhance user experience, and develop new features and services based on user feedback and behavior analytics.
• Responsible Gaming: To monitor player behavior for signs of problem gambling, enforce self-exclusion requests, and apply deposit limits, loss limits, and session time limits as requested by you or as required by our Responsible Gaming Policy.

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

For users in jurisdictions subject to the General Data Protection Regulation (GDPR) or similar data protection laws, we process your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and 23naga (our Terms & Conditions), including account creation, transaction processing, and service delivery.
• Legal Obligation: Processing is required to comply with legal obligations, including KYC and AML verification, tax reporting, and regulatory compliance.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security monitoring, platform improvement, and customer support, provided that such interests do not override your fundamental rights and freedoms.
• Consent: Where required by law, we obtain your explicit consent before processing certain types of personal data, such as sending marketing communications or using cookies for analytics and advertising purposes.

5. Data Sharing and Disclosure

23naga does not sell, rent, or trade your personal information to third parties for marketing purposes. However, we may share your personal data with the following categories of recipients under specific circumstances:

5.1 Service Providers and Business Partners

We engage trusted third-party service providers to assist with the operation of the Platform, including:

• Payment Processors: Banks and e-wallet providers (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, LinkAja) process your deposits and withdrawals on our behalf.
• Game Providers: Third-party software providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft, etc.) deliver casino and slot games through our Platform.
• KYC and Fraud Prevention Services: Identity verification and fraud detection services assist with account verification, AML compliance, and risk management.
• Cloud Hosting and IT Infrastructure: Cloud service providers host our servers, databases, and backup systems to ensure Platform availability and data redundancy.
• Customer Support Tools: Live chat, helpdesk, and CRM platforms enable our support team to assist you efficiently.

All third-party service providers are contractually obligated to protect your personal data, use it only for the purposes specified by us, and comply with applicable data protection laws. We conduct due diligence to ensure that our partners maintain adequate security standards.

5.2 Legal and Regulatory Authorities

We may disclose your personal information to government authorities, law enforcement agencies, or regulatory bodies if required by law, including:

• In response to a valid subpoena, court order, warrant, or other legal process.
• To comply with anti-money laundering (AML), counter-terrorism financing (CTF), or tax reporting obligations.
• To enforce our Terms & Conditions, prevent fraud, or protect the rights, property, or safety of 23naga, our users, or the public.
• In connection with a criminal investigation, regulatory audit, or legal dispute.

5.3 Business Transfers

In the event of a merger, acquisition, sale of assets, or other corporate restructuring, your personal data may be transferred to the acquiring entity or successor company. We will notify you of any such transfer and ensure that the receiving party agrees to protect your data in accordance with this Privacy Policy.

6. Data Retention

We retain your personal information 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 include:

• Account Data: Retained for the duration of your active account and for up to 5 years after account closure for legal, regulatory, and audit purposes.
• Transaction Records: Retained for at least 5 years to comply with financial recordkeeping and tax reporting requirements.
• KYC Documents: Retained for at least 5 years after account closure as required by anti-money laundering (AML) regulations.
• Communication Records: Retained for up to 3 years for customer support quality assurance and dispute resolution purposes.
• Usage Logs: Retained for up to 1 year for security monitoring and fraud prevention.

After the applicable retention period expires, we will securely delete or anonymize your personal data in accordance with data protection best practices.

7. Data Security

23naga implements industry-standard technical and organizational security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS encryption (the same standard used by major international banks).
• Secure Storage: Personal data is stored on secure servers with restricted access controls, firewalls, and intrusion detection systems.
• Password Protection: User passwords are hashed and salted using industry-standard cryptographic algorithms (bcrypt or Argon2) to prevent unauthorized access.
• Access Controls: Only authorized personnel with a legitimate need to access your data (e.g., customer support, compliance officers) are granted access, and all access is logged and monitored.
• Regular Security Audits: We conduct regular security audits, penetration testing, and vulnerability assessments to identify and address potential security risks.
• Employee Training: All employees are trained on data protection principles and are bound by confidentiality agreements.

While we take all reasonable steps to protect your data, no method of transmission over the Internet or electronic storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect unauthorized access to your account.

8. Cookies and Tracking Technologies

23naga uses cookies, web beacons, and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver personalized content. A cookie is a small text file stored on your device by your web browser. Cookies do not contain personal information but may be linked to your account to provide a customized experience.

8.1 Types of Cookies We Use

• Essential Cookies: Required for basic Platform functionality, such as login authentication, session management, and security features. These cookies cannot be disabled.
• Performance Cookies: Collect anonymous usage data to help us understand how users interact with the Platform, identify errors, and improve performance.
• Functional Cookies: Remember your preferences (language, currency, game favorites) to provide a more personalized experience.
• Advertising Cookies: Track your browsing activity to deliver targeted advertisements and measure the effectiveness of marketing campaigns (with your consent where required by law).

8.2 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to block or delete cookies, but doing so may affect your ability to use certain features of the Platform. You can also opt out of targeted advertising by adjusting your cookie preferences in our cookie consent banner (if applicable) or by using industry opt-out tools such as the Network Advertising Initiative (NAI) opt-out page.

9. Your Privacy Rights

Depending on your jurisdiction, you may have certain rights regarding your personal data, including:

• Right to Access: You may request a copy of the personal data we hold about you, including information about how we use it and who we share it with.
• Right to Rectification: You may request that we correct any inaccurate or incomplete personal data.
• Right to Erasure (Right to be Forgotten): You may request that we delete your personal data, subject to legal retention requirements and legitimate business needs.
• Right to Restrict Processing: You may request that we limit the processing of your personal data in certain circumstances (e.g., if you dispute the accuracy of the data).
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format for transfer to another service provider.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes or based on legitimate interests.
• Right to Withdraw Consent: If we process your personal data based on your consent (e.g., for marketing communications), you may withdraw your consent at any time.

To exercise any of these rights, please contact our support team at [email protected] (text only, not clickable) or via live chat. We will respond to your request within the timeframe required by applicable law (typically 30 days).

10. Children's Privacy

The Platform is intended for adults aged 21 and over. We do not knowingly collect personal information from individuals under the age of 21. If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete such information and close the associated account. If you believe that a minor has provided us with personal data, please contact us immediately at [email protected].

11. International Data Transfers

23naga operates from servers located in multiple jurisdictions to ensure Platform availability and performance. Your personal data may be transferred to, stored, and processed in countries outside of Indonesia. When we transfer your data internationally, we ensure that appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs), adequacy decisions, or other legally recognized transfer mechanisms, to protect your data in accordance with applicable data protection laws.

12. Third-Party Links

The Platform may contain links to third-party websites, including game provider sites, payment processor portals, and social media platforms. This Privacy Policy applies only to 23naga. We are not responsible for the privacy practices or content of third-party websites. We encourage you to review the privacy policies of any third-party sites you visit.

13. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. When we make material changes, we will notify you by posting a notice on the Platform or by sending an email to the address associated with your account (if applicable). Your continued use of the Platform after any changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this page periodically to stay informed of how we protect your data.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact us:

• Email: [email protected] (text only, not clickable)
• Live Chat: Available 24/7 via the chat icon on our website
• Mailing Address: [If applicable, physical address can be listed here for legal compliance purposes]

Our customer support team is available around the clock and will respond to your inquiry as quickly as possible. For data protection inquiries specifically, please mark your message as "Privacy Request" to expedite processing.