At ipo38, your privacy is treated with the same seriousness as platform security. This Privacy Policy explains precisely what personal data we collect from Indonesian members, why we collect it, how it is used and stored, and what rights you hold over your own information.
Our Privacy Commitments
Before reading the full legal text, these six principles summarise the approach ipo38 takes to every data decision involving member information.
ipo38 does not collect personal data for its own sake. Every data point we request — from your name and date of birth during registration to your bank account details during withdrawal — has a specific, documented purpose tied to operating a safe and compliant platform.
ipo38 does not sell, rent, or trade your personal data to any third party for marketing or commercial purposes. Your information is shared only with the service providers and partners strictly necessary to operate the ipo38 platform — and only under binding confidentiality agreements.
All personal and financial data transmitted between your device and the ipo38 platform is protected by 256-bit SSL/TLS encryption. Account passwords are stored using one-way cryptographic hashing — ipo38 staff cannot read your password, and it is never stored in plain text.
ipo38 members have the right to access a copy of the personal data held about them, request corrections to inaccurate information, and — subject to legal retention obligations — request deletion of data when it is no longer necessary for platform operations. Contact [email protected] to exercise these rights.
Personal data is retained by ipo38 for as long as your account remains active and for a legally mandated period after account closure — typically five years for financial and KYC records in accordance with standard international anti-money-laundering retention requirements. Marketing preferences are cleared upon account closure.
If ipo38 makes a material change to this Privacy Policy — one that meaningfully affects how your data is used — we will notify you by email to your registered address at least 14 days before the change takes effect. The updated policy will always be available at ipo38.bet/privacy-policy.
The following terms carry specific meanings throughout this Privacy Policy:
2.1 This Privacy Policy applies to all Personal Data collected by ipo38 in connection with the operation of the ipo38 Platform, including data collected during account registration, KYC verification, deposits, withdrawals, customer support interactions, and general browsing of the Platform.
2.2 This Privacy Policy applies to all members and visitors, regardless of the device or browser used to access the ipo38 Platform.
2.3 This Privacy Policy does not apply to third-party websites or services that may be linked to or from the ipo38 Platform. ipo38 is not responsible for the privacy practices of those third parties, and we encourage you to review their respective privacy policies before providing any personal data to them.
2.4 The ipo38 Platform is directed at and intended for use by individuals resident in Indonesia. By using the Platform from Indonesia, you acknowledge that your data is being processed in accordance with this Privacy Policy and applicable international data protection standards.
ipo38 collects the following categories of Personal Data, depending on how you interact with the Platform:
| Category | Specific Data Points | When Collected |
|---|---|---|
| Identity Data | Full legal name, date of birth, Indonesian national identity number (NIK), gender | Registration & KYC |
| Contact Data | Email address, Indonesian mobile phone number, residential address | Registration |
| Financial Data | Bank account name and number (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata), e-wallet account (OVO, DANA, GoPay, ShopeePay, LinkAja), transaction history, deposit and withdrawal records | Deposits & Withdrawals |
| KYC Documents | Scanned or photographed copies of government-issued ID (KTP / Passport), proof-of-address documents | KYC Verification |
| Usage Data | Pages visited, games played, bets placed, session duration, click-path data, search queries on Platform | Continuous browsing & play |
| Technical Data | IP address, device type and model, operating system, browser type and version, screen resolution, time-zone setting (WIB / WITA / WIT) | Every Platform visit |
| Communications Data | Records of live-chat conversations, email correspondence, and support-ticket submissions with ipo38 customer service | Customer support interactions |
| Marketing Preferences | Opt-in / opt-out status for promotional emails and SMS notifications | Registration & account settings |
ipo38 collects Personal Data through the following mechanisms:
ipo38 uses the Personal Data it collects strictly for the following purposes:
| Purpose | Data Used |
|---|---|
| Account creation and management | Identity Data, Contact Data |
| Age and identity verification (KYC) | Identity Data, KYC Documents |
| Processing deposits and withdrawals | Financial Data, Identity Data |
| Fraud prevention and platform security | Technical Data, Financial Data, Usage Data |
| Providing customer support | Communications Data, Identity Data |
| Personalising platform experience | Usage Data, Technical Data |
| Sending promotional communications (opt-in only) | Contact Data, Marketing Preferences |
| Responsible gaming monitoring | Usage Data, Financial Data |
| Legal and regulatory compliance | Identity Data, Financial Data, KYC Documents |
| Platform analytics and product improvement | Usage Data, Technical Data (anonymised) |
ipo38 processes your Personal Data on the following legal bases:
7.1 We Do Not Sell Your Data. ipo38 does not sell, rent, or trade your Personal Data to any third party for commercial or marketing purposes. Period.
7.2 Sharing with Third-Party Processors. ipo38 may share your Personal Data with the following categories of trusted third-party processors, each bound by a data-processing agreement that restricts them to processing your data only on ipo38's documented instructions:
7.3 Disclosure Required by Law. ipo38 may disclose your Personal Data to governmental or regulatory authorities where required to do so by law, court order, or lawful regulatory request. ipo38 will, where legally permitted, notify the affected member of such a request before disclosure.
7.4 Business Transfers. In the event of a merger, acquisition, or sale of all or a portion of ipo38's business assets, your Personal Data may be transferred to the acquiring entity as part of that transaction. ipo38 will provide notice via the Platform and by email before your data is transferred and becomes subject to a different privacy policy.
8.1 What Are Cookies. Cookies are small text files stored on your device when you visit the ipo38 Platform. They allow the Platform to remember your preferences, maintain your login session, and collect anonymised usage data. ipo38 uses cookies and similar technologies including pixel tags and local storage.
8.2 Types of Cookies Used by ipo38:
| Cookie Type | Purpose | Duration |
|---|---|---|
| Strictly Necessary | Maintain your login session, remember your cart and game state, enable security features. These cannot be disabled without breaking core Platform functionality. | Session |
| Functional | Remember your display preferences (language, time-zone display, notification settings) so you do not need to re-enter them each visit. | Up to 12 months |
| Analytics | Collect anonymised data about how members navigate the Platform — pages visited, session length, click paths — to help ipo38 improve usability. Data is aggregated and never linked to individual profiles. | Up to 24 months |
| Security / Fraud Detection | Detect suspicious login behaviour, bot activity, and multi-account creation attempts. Essential to platform integrity and member protection. | Up to 6 months |
8.3 Managing Cookies. You can control cookie settings through your browser's privacy or settings menu. Disabling strictly necessary cookies will impair your ability to log in and use the ipo38 Platform. Disabling analytics or functional cookies will not prevent you from accessing the Platform but may reduce the quality of your experience.
9.1 ipo38 retains Personal Data only for as long as is necessary to fulfil the purpose for which it was collected, subject to any longer period required by law.
9.2 Retention Periods:
9.3 Upon expiry of the relevant retention period, ipo38 will securely delete or permanently anonymise the data using industry-standard methods.
10.1 ipo38 implements a layered security framework to protect your Personal Data against unauthorised access, disclosure, alteration, and destruction. Key measures include:
10.2 Notwithstanding the above, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. ipo38 will notify affected members without undue delay in the event of a data breach that poses a risk to your rights and freedoms.
As an ipo38 member, you hold the following rights over your Personal Data. To exercise any of these rights, please submit a written request to [email protected]. ipo38 will respond within 30 calendar days of receiving a valid request.
12.1 The ipo38 Platform is strictly intended for individuals aged 21 and over. ipo38 does not knowingly collect Personal Data from anyone under the age of 21.
12.2 If ipo38 discovers or is notified that an account has been registered by or on behalf of an individual under 21 years of age, that account will be immediately closed, any balance forfeited, and all associated Personal Data deleted or anonymised within 30 days, except where retention is required for fraud investigation or legal compliance purposes.
12.3 If you are a parent or guardian and believe that a minor has registered an ipo38 account, please contact [email protected] immediately with supporting information so that ipo38 can take prompt action.
13.1 The ipo38 Platform integrates third-party game content from providers including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Pocket Games Soft. When you launch a game from one of these providers, a connection is established directly between your device and the provider's servers. These providers operate under their own privacy policies, and ipo38 recommends reviewing those policies to understand their data practices.
13.2 The ipo38 Platform may contain links to external websites (for example, links to sport governing body websites for event results). ipo38 is not responsible for the content or privacy practices of those external sites, and this Privacy Policy does not apply to them.
13.3 All third-party processors engaged by ipo38 are required to maintain appropriate technical and organisational security measures and to process Personal Data only in accordance with ipo38's documented instructions.
14.1 ipo38's Platform infrastructure and some of its third-party processors may be located outside Indonesia. Where Personal Data is transferred internationally, ipo38 takes steps to ensure that appropriate safeguards are in place to protect the data to a standard at least equivalent to the protections described in this Privacy Policy.
14.2 Such safeguards may include data-processing agreements incorporating standard contractual clauses, transfers to processors operating under internationally recognised data protection frameworks, or transfers covered by a recognised adequacy assessment.
14.3 If you would like further information about the specific safeguards applied to international transfers of your Personal Data, please contact ipo38 at [email protected].
15.1 ipo38 reserves the right to update this Privacy Policy at any time. The most current version will always be published at ipo38.bet/privacy-policy, with the "Last updated" date revised accordingly.
15.2 Where an amendment constitutes a material change to how ipo38 processes your Personal Data, ipo38 will notify you by email to your registered address at least 14 days before the change takes effect. For minor, non-material amendments (such as clarifications of existing language or corrections to typographical errors), ipo38 may update the policy without prior notice.
15.3 Your continued use of the ipo38 Platform following the effective date of any amendment constitutes acceptance of the revised Privacy Policy. If you do not accept the revised policy, please discontinue use of the Platform and contact [email protected] to arrange account closure.
16.1 Data-Related Enquiries. If you have any question about this Privacy Policy, wish to exercise a privacy right described in Clause 11, or have a concern about how ipo38 is handling your Personal Data, please contact the ipo38 data team:
ipo38 will acknowledge your request within 3 business days (WIB) and provide a substantive response within 30 calendar days of receiving all information necessary to process it.
16.2 Complaints. If you believe ipo38 has not handled your Personal Data in accordance with this Privacy Policy, ipo38 encourages you to raise your concern directly with the support team in the first instance. ipo38 is committed to resolving privacy complaints fairly and promptly. If you remain dissatisfied after ipo38's internal review, you have the right to escalate the matter to the relevant data protection authority or competent supervisory body in your jurisdiction.
16.3 Related Policies. This Privacy Policy should be read alongside the ipo38 Terms & Conditions and the Responsible Gaming policy, which together form the full framework governing your use of the ipo38 Platform.
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