Privacy Policy — suhu79 Platform

suhu79 operates the online betting and gaming platform accessible at suhu79.app (the "Platform"). For the purposes of this Privacy Policy, suhu79 acts as the data controller — meaning we are the entity that determines the purposes for which, and the means by which, your personal data is processed.

suhu79 is designed and operated specifically for the Indonesian market, serving players across Jakarta, Surabaya, Bandung, Medan, Yogyakarta, Bali, Semarang, Makassar, and beyond. Our Platform offers sportsbook betting, live casino, slots, togel (Indonesia's traditional numbers lottery), Domino QQ, and Bingo Online — all conducted in Indonesian Rupiah (IDR).

Questions about this Privacy Policy or about how we handle your data should be directed to our support team at [email protected]. We are committed to responding to all privacy-related enquiries within 5 business days.

suhu79 collects the following categories of personal data. We only collect data that is necessary for the stated purpose — we do not collect categories of sensitive data beyond what our KYC and responsible gaming obligations require.

suhu79 collects personal data through the following channels and mechanisms:

• Direct submission. Data you provide when you register an account, complete KYC verification, make a deposit or withdrawal request, contact our support team, or respond to a promotional survey.
• Automated collection. Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, and server logs. See Section 7 (Cookies & Tracking) for full details.
• Third-party verification providers. Identity and age verification data received from our KYC service partners when you submit a verification request. These providers cross-reference your submitted documents against authoritative Indonesian identity databases.
• Payment processors. Transaction confirmation data received from our payment processing partners following a deposit or withdrawal. We receive confirmation of transaction status and reference numbers; we do not receive your full banking credentials directly from processors.
• Fraud and security tools. Risk-scoring data generated by our anti-fraud systems based on device fingerprinting, IP reputation analysis, and behavioural pattern recognition.

suhu79 uses your personal data for the following specific purposes. We do not use your data in ways that are incompatible with these stated purposes without first obtaining your consent or having a separate legal basis to do so.

• Account creation and management. To register your account, maintain your player profile, manage your IDR wallet balance, and keep your account records accurate and up to date.
• Identity and age verification (KYC). To confirm that you are who you say you are, that you are at least 21 years of age, and that you are a resident of Indonesia — as required by our responsible gaming and player protection policies.
• Transaction processing. To process deposits via local Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja), and to process withdrawal requests to your registered payment method.
• Customer support. To respond to your enquiries, resolve complaints, and manage dispute resolution processes, whether submitted via live chat or email.
• Responsible gaming. To monitor your gameplay patterns for signs of problematic gambling behaviour, to enforce self-exclusion requests, and to apply deposit limits and cool-off periods where requested or where our systems identify a concern.
• Platform security and fraud prevention. To detect and prevent unauthorised account access, bonus abuse, money laundering, collusion, and other forms of fraudulent activity. This includes automated profiling of account behaviour for risk-scoring purposes.
• Legal and regulatory compliance. To maintain records required for anti-money laundering (AML) compliance, to respond to lawful requests from competent authorities, and to fulfil our obligations under applicable international gaming regulations.
• Marketing and promotions (opt-in only). To send you personalised promotional offers, bonus notifications, and information about seasonal campaigns (such as Idul Fitri promotions, Ramadhan offers, and Indonesian Independence Day events on 17 August) — but only where you have opted in to marketing communications. You may withdraw consent at any time.
• Platform improvement and analytics. To analyse usage patterns, identify technical issues, optimise game performance, and improve the overall player experience on suhu79.

suhu79 processes your personal data on the following legal bases:

• Contractual necessity. Processing required to perform our contract with you — including account registration, KYC verification, transaction processing, and customer support — is carried out on the basis of contractual necessity. Without this processing, we cannot provide the Platform services to you.
• Legitimate interests. Processing carried out for fraud prevention, security monitoring, platform analytics, and responsible gaming monitoring is conducted on the basis of our legitimate interest in operating a safe, secure, and responsible betting platform. We have assessed that these interests are not overridden by your rights and freedoms in each case.
• Legal obligation. Processing required to comply with AML regulations, respond to lawful authority requests, and maintain mandated financial records is carried out on the basis of legal obligation.
• Consent. Processing for direct marketing purposes is carried out only on the basis of your explicit, freely given consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

suhu79 does not sell your personal data. We may share your data with the following categories of third parties, strictly on a need-to-know basis and subject to contractual data-protection obligations:

• KYC and identity verification providers. Specialist providers who verify your identity documents and confirm your age and residency as part of our player registration process.
• Payment processors and banking partners. Financial institutions and payment gateway operators who facilitate your deposit and withdrawal transactions. These include our banking integrations with BCA, BRI, BNI, Mandiri, CIMB Niaga, and e-wallet platforms (OVO, DANA, GoPay, ShopeePay, LinkAja). These parties receive only the data necessary to execute the transaction.
• Game content providers. Studios such as Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive anonymised session identifiers to facilitate game delivery and fair-play auditing. These providers do not receive your personal identity information.
• Anti-fraud and security services. Third-party risk and fraud detection services that analyse transaction patterns and device signals to protect the Platform and its players.
• IT infrastructure providers. Cloud hosting, database management, and platform infrastructure providers who store and process data on suhu79's behalf under data processing agreements.
• Legal and regulatory authorities. Competent government authorities or law enforcement agencies where suhu79 is required to disclose data by law, court order, or other lawful process. suhu79 will, where legally permitted, notify you of any such disclosure.

suhu79 uses cookies and similar tracking technologies on the Platform to ensure correct functionality, maintain your session state, analyse usage, and support fraud prevention. The following categories of cookies are used:

• Strictly necessary cookies. These are required for the Platform to function. They maintain your login session, remember your language and currency preferences, and support security features. These cookies cannot be disabled without breaking core Platform functionality.
• Functional cookies. These remember your preferences — such as your preferred deposit method or game lobby layout — to provide a more personalised experience. They are not strictly necessary but improve usability.
• Analytical cookies. These collect anonymised data about how players use the Platform — which pages are most visited, how long sessions last, and where players encounter errors — to help us improve the site.
• Security and fraud-prevention cookies. These assign a unique device identifier to your session, which our systems use to detect unusual behaviour, identify multiple-account abuse, and flag suspicious login attempts.

suhu79 does not use advertising or retargeting cookies. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies will prevent you from logging in to your suhu79 account.

suhu79 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation. Our standard retention periods are as follows:

When the applicable retention period expires, data is securely deleted or anonymised so that it can no longer be linked to an individual player.

As a suhu79 player, you have the following rights in relation to your personal data. To exercise any of these rights, contact our support team at [email protected] with the subject line "Data Rights Request" and a description of the specific right you wish to exercise.

• Right of access. You may request a copy of all personal data we hold about you, together with information about how it is being used. We will provide this within 30 calendar days of receiving a verified request.
• Right to rectification. You may request correction of any inaccurate or incomplete personal data we hold. In some cases, you can update data directly within your account profile.
• Right to erasure ("right to be forgotten"). You may request deletion of your personal data. We will fulfil this request where no legal obligation requires us to retain the data. Where retention is legally required (e.g., AML transaction records), we will inform you of the specific obligation and the expected retention period.
• Right to restrict processing. You may request that we limit how we use your data while a dispute about its accuracy or the lawfulness of our processing is resolved.
• Right to data portability. You may request a machine-readable copy of data you have provided to us directly, in a structured and commonly used format.
• Right to object. You may object at any time to processing of your data for direct marketing purposes. You may also object to processing carried out on the basis of legitimate interests; we will assess whether our interests are overridden in your specific case.
• Right to withdraw consent. Where we process data on the basis of your consent (primarily for marketing), you may withdraw that consent at any time through your account settings or by contacting support. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

suhu79 operates a strict 21+ only policy. The Platform is not intended for, and must not be accessed by, any person under the age of 21. We do not knowingly collect personal data from individuals under 21 years of age.

During registration, all players are required to declare that they are 21 or older. suhu79 enforces this through mandatory KYC age verification before any real-money play is permitted. Where our systems or review processes identify a player who may be under 21, the account will be immediately suspended pending verification. If verification confirms the player is under 21, the account will be permanently closed and any balance returned to the originating payment method after deduction of any bonus funds.

If you are a parent or guardian and believe that a person under 21 in your care has registered a suhu79 account, please contact us immediately at [email protected]. We will prioritise the review and closure of any such account.

suhu79 implements a comprehensive suite of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include, but are not limited to:

• Transport Layer Security (TLS 1.3). All data transmitted between your device and suhu79's servers is encrypted in transit using TLS 1.3, preventing interception by third parties.
• Data encryption at rest. Sensitive personal data — including identity documents and financial information — is encrypted at rest using AES-256 encryption within our secure database infrastructure.
• Access controls. Access to player data within suhu79's internal systems is strictly role-based and limited to personnel who require it to fulfil specific, defined job functions. All internal data access is logged and audited.
• Two-factor authentication (2FA). suhu79 supports and encourages the use of two-factor authentication for player accounts as an additional layer of protection against unauthorised login.
• Penetration testing and vulnerability management. suhu79's Platform undergoes regular independent security assessments to identify and remediate vulnerabilities before they can be exploited.
• Incident response. In the event of a data breach that poses a risk to your rights and freedoms, suhu79 will notify affected players promptly and take immediate steps to contain and mitigate the breach.

While suhu79 takes every reasonable precaution to protect your data, no internet-based platform can guarantee absolute security. You also bear responsibility for maintaining the security of your own account credentials. Do not share your password with anyone, and contact support immediately if you suspect unauthorised access to your account.

suhu79 serves the Indonesian market and stores the majority of player data within secure data centre infrastructure. In certain circumstances — for example, where game content providers such as Evolution Gaming or Pragmatic Play deliver live casino streams hosted on servers in other jurisdictions — your session data may be processed outside Indonesia.

Where such international transfers occur, suhu79 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that applied within Indonesia, including contractual data protection clauses with all relevant data processors and sub-processors.

suhu79 does not transfer your identity data, KYC documents, or financial data to jurisdictions outside the operating infrastructure without your knowledge and without appropriate protective measures in place.

suhu79 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform functionality. The "Last Updated" date at the top of this page will be revised each time a change is made.

For material changes — those that significantly affect how we collect, use, or share your personal data — we will provide at least 14 days' advance notice via in-platform notification or email to your registered address, giving you the opportunity to review the changes before they take effect.

Your continued use of the Platform following the effective date of any updated Privacy Policy constitutes your acknowledgement of the revised terms. If you disagree with any material change, you may close your account before the change takes effect by contacting our support team.

For any questions, concerns, or requests relating to this Privacy Policy or to the way suhu79 handles your personal data, please contact our dedicated privacy support team using the details below:

• Email: [email protected] — use the subject line "Privacy Enquiry" or "Data Rights Request" for fastest routing.
• Live Chat: Available 24 hours a day, 7 days a week through the suhu79 Platform. Our Indonesian-speaking support agents are available around the clock.
• Response commitment: We acknowledge all privacy-related enquiries within 5 business days (WIB, UTC+7) and aim to resolve them fully within 30 calendar days.

If you are dissatisfied with our handling of your personal data or your data rights request, you have the right to escalate your complaint to the relevant supervisory authority. suhu79 is committed to resolving all data-related concerns fairly and transparently, and we encourage you to contact us directly in the first instance so we can work toward a resolution.