Privacy Policy

1. Introduction

atom88 ("we", "us", "our") operates the online gaming platform accessible at https://atom88.cam. We are committed to protecting and respecting your privacy in accordance with applicable data protection laws and international best practices. This Privacy Policy explains what personal data we collect from you, how we use it, who we share it with, how we protect it, and your rights regarding your personal information.

This policy applies to all users of the atom88 platform, including registered members and visitors. By accessing or using our services, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

If you do not agree with this Privacy Policy, you must immediately cease using our platform. For users in Indonesia, we process data in compliance with both international standards and local Indonesian data protection practices.

2. Data Controller

atom88 is the data controller responsible for the personal data you provide to us. As the data controller, we determine how and why your personal data is processed. We are responsible for ensuring that your data is processed lawfully, fairly, and transparently.

For any questions, concerns, or requests regarding your personal data or this Privacy Policy, you may contact our Data Protection Officer at the contact details provided in Section 13 of this policy.

3. Personal Data We Collect

To provide our gaming services, comply with legal obligations, and ensure platform security, we collect various categories of personal data:

3.1 Account Registration Information

• Identity Information: Full legal name, date of birth, gender, nationality.
• Contact Information: Email address, mobile phone number, residential address, postal code.
• Account Credentials: Username, password (stored in encrypted form), security questions and answers.

3.2 Verification and KYC Documents

• Government-Issued Identification: Indonesian National Identity Card (KTP) or Passport, including photograph, ID number, issue date, and expiry date.
• Proof of Address: Utility bills, bank statements, or government correspondence dated within the last three months.
• Selfie Verification: Photograph of you holding your ID card for identity confirmation.
• Additional Documents: In rare cases, we may request additional documentation to verify your identity or comply with regulatory requirements.

3.3 Financial Information

• Bank Account Details: Bank name, account number, account holder name for deposits and withdrawals.
• E-Wallet Information: E-wallet provider name, registered mobile number, and account name (for OVO, DANA, GoPay, ShopeePay, LinkAja).
• Transaction History: Records of all deposits, withdrawals, wagers, winnings, bonuses claimed, and account balances.
• Payment Methods: Information about the payment methods you use, including timestamps and transaction reference numbers.

3.4 Gaming and Behavioral Data

• Gaming Activity: Records of games played, bets placed, outcomes, winnings, losses, bonus utilization, and gaming preferences.
• Login History: Dates and times of account logins, IP addresses used, device types, operating systems, and browser information.
• Communication Records: Transcripts of live chat conversations, emails exchanged with customer support, WhatsApp messages, and phone call recordings (with notification).
• Marketing Preferences: Your communication preferences, consent status for marketing emails, SMS notifications, and promotional offers.

3.5 Technical and Device Information

• Device Data: Device type, operating system, browser type and version, screen resolution, language settings.
• Connection Data: IP address, internet service provider, geographic location (city-level), time zone.
• Cookies and Tracking: Session cookies, authentication tokens, analytics cookies, and similar technologies (see Section 11).

4. How We Collect Your Data

We collect personal data through various methods during your interaction with our platform:

• Direct Provision: When you voluntarily provide information during account registration, KYC verification, deposits, withdrawals, or communication with customer support.
• Automated Collection: Through cookies, web beacons, and similar technologies that automatically collect technical data when you visit our website or use our services.
• Third-Party Sources: From payment processors (BCA, BRI, BNI, Mandiri, and e-wallet providers) for transaction verification, and from identity verification service providers for KYC compliance.
• Public Sources: In rare cases, from publicly available sources such as business directories or government registries to verify information you provide.

5. Purpose of Data Processing

atom88 processes your personal data for the following specific purposes:

5.1 Service Provision

• Create, maintain, and manage your gaming account.
• Process deposits, withdrawals, and financial transactions.
• Provide access to sports betting, casino games, slots, and other gaming services.
• Calculate, credit, and debit wagers, winnings, bonuses, and account balances.
• Deliver customer support via live chat, email, WhatsApp, and phone.

5.2 Legal and Regulatory Compliance

• Verify your identity and age (21+ requirement) through KYC procedures.
• Comply with anti-money laundering (AML) and counter-terrorism financing (CTF) obligations.
• Maintain records as required by gaming license regulations.
• Respond to lawful requests from government authorities, law enforcement, or courts.
• Prevent fraud, money laundering, underage gambling, and illegal activity.

5.3 Security and Fraud Prevention

• Monitor for suspicious account activity, duplicate accounts, and unauthorized access.
• Detect and prevent bonus abuse, collusion, and other prohibited activities.
• Protect the integrity of our games and platform through RNG verification and anti-cheating measures.
• Investigate disputes, complaints, and potential policy violations.

5.4 Marketing and Communications

• Send promotional offers, bonuses, tournament announcements, and newsletters (with your consent).
• Personalize your gaming experience based on your preferences and activity.
• Conduct player satisfaction surveys and gather feedback.
• Deliver important account notifications, policy updates, and security alerts (even if you opt out of marketing).

5.5 Analytics and Improvement

• Analyze gaming trends, user behavior, and platform performance.
• Improve game selection, user interface, and customer experience.
• Test new features, betting markets, and promotional strategies.
• Generate aggregated, anonymized statistics for business intelligence (these reports do not identify individual users).

6. Legal Basis for Data Processing

Under international data protection law, we must have a lawful basis for processing your personal data. We rely on the following legal grounds:

• Contractual Necessity: Processing is necessary to fulfill our contract with you (providing gaming services, processing transactions, managing your account).
• Legal Obligation: Processing is required to comply with legal requirements such as KYC, AML, age verification, and record-keeping mandates.
• Legitimate Interests: Processing is necessary for our legitimate business interests (fraud prevention, security, platform improvement, internal analytics) provided these interests do not override your fundamental rights.
• Consent: For marketing communications, optional data processing, and cookies (where required), we obtain your explicit consent, which you may withdraw at any time.

7. Data Sharing and Third-Party Disclosure

atom88 does not sell, rent, or trade your personal data to third parties for their marketing purposes. However, we may share your data with the following categories of recipients when necessary:

7.1 Service Providers

• Payment Processors: Banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay, ShopeePay) to process deposits and withdrawals.
• Identity Verification Services: Third-party KYC/AML verification providers to confirm your identity and comply with regulatory requirements.
• Technology Partners: Hosting providers, cloud storage services, cybersecurity firms, and IT maintenance contractors.
• Customer Support Tools: Live chat platforms, email service providers, and CRM systems to deliver customer service.
• Analytics Providers: Services that help us analyze website traffic, user behavior, and platform performance (data is typically anonymized).

7.2 Game Providers

We share limited data (username, bet amounts, game outcomes) with third-party game studios and live casino providers to deliver gaming content. These providers are contractually obligated to protect your data and use it only for service delivery.

7.3 Legal and Regulatory Authorities

We may disclose your personal data to government agencies, law enforcement, courts, or regulatory bodies when:

• Required by law, court order, subpoena, or other legal process.
• Necessary to comply with our gaming license obligations.
• Required for AML/CTF reporting or suspicious activity reports.
• Necessary to protect our rights, property, or safety, or the rights and safety of our users or the public.

7.4 Business Transfers

In the event of a merger, acquisition, sale of assets, or bankruptcy, your personal data may be transferred to the acquiring entity. We will notify you of any such transfer and any changes to this Privacy Policy.

7.5 Data Processing Agreements

All third-party service providers with access to your personal data are bound by strict data processing agreements that require them to protect your data, use it only for specified purposes, and comply with applicable data protection laws.

8. Data Security Measures

atom88 employs comprehensive technical and organizational security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction:

• Encryption: All data transmissions between your device and our servers are encrypted using industry-standard SSL/TLS protocols. Sensitive data (passwords, financial information) is encrypted at rest using AES-256 encryption.
• Access Controls: Personal data is accessible only to authorized employees and contractors who require access to perform their job functions. Access is granted on a need-to-know basis and protected by multi-factor authentication.
• Secure Infrastructure: Our servers are hosted in secure, certified data centers with physical security controls, redundant power supplies, and 24/7 monitoring.
• Firewalls and Intrusion Detection: Network firewalls, intrusion detection systems, and regular security audits protect against cyber threats.
• Regular Security Testing: We conduct regular penetration testing, vulnerability assessments, and security audits to identify and remediate potential weaknesses.
• Employee Training: All employees receive regular training on data protection, privacy, and security best practices.
• Incident Response Plan: We maintain a documented incident response plan to address any data breaches promptly and effectively.

While we implement robust security measures, no system is entirely immune to security risks. You also have a responsibility to protect your account by choosing a strong password, not sharing your login credentials, and reporting any suspicious activity immediately.

9. Data Retention Period

atom88 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements:

Data Category	Retention Period
Account Information	Duration of account + 7 years after closure
KYC Documents	7 years after account closure (regulatory requirement)
Transaction Records	7 years after transaction date (financial regulations)
Gaming Activity Logs	5 years (dispute resolution and compliance)
Marketing Consent Records	Duration of consent + 2 years
Customer Support Records	3 years after last interaction
Technical Logs (IP addresses, device data)	1-2 years (security and troubleshooting)

After the retention period expires, personal data is securely deleted or anonymized so that it can no longer identify you. If you close your account, we retain certain data for legal and regulatory compliance purposes, but your account will be marked as inactive and you will no longer receive marketing communications.

10. Your Rights Regarding Your Personal Data

Under applicable data protection laws, you have the following rights concerning your personal data:

10.1 Right of Access

You have the right to request a copy of the personal data we hold about you. We will provide this information in a structured, commonly used, and machine-readable format within 30 days of your request.

10.2 Right to Rectification

If your personal data is inaccurate or incomplete, you have the right to request that we correct or update it. You can update most information directly through your account settings.

10.3 Right to Erasure ("Right to be Forgotten")

You may request deletion of your personal data under certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, or when you withdraw consent. However, we may be required to retain certain data for legal, regulatory, or security reasons.

10.4 Right to Restrict Processing

You have the right to request that we restrict the processing of your personal data in certain situations, such as when you contest the accuracy of the data or object to our processing.

10.5 Right to Data Portability

Where technically feasible, you have the right to receive your personal data in a portable format and transmit it to another service provider.

10.6 Right to Object

You have the right to object to processing of your personal data based on legitimate interests or for direct marketing purposes. You can opt out of marketing communications at any time by clicking the unsubscribe link in our emails or contacting customer support.

10.7 Right to Withdraw Consent

Where we process your data based on consent (e.g., marketing communications, optional cookies), you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

10.8 Exercising Your Rights

To exercise any of these rights, please contact our Data Protection Officer using the contact details in Section 13. We will respond to your request within 30 days. We may ask you to verify your identity before processing your request to ensure data security.

11. Cookies and Tracking Technologies

atom88 uses cookies and similar tracking technologies to enhance your experience, analyze platform usage, and deliver personalized content:

11.1 What Are Cookies?

Cookies are small text files stored on your device by your web browser when you visit our website. They allow us to recognize your device, remember your preferences, and understand how you use our platform.

11.2 Types of Cookies We Use

• Essential Cookies: Necessary for the platform to function (login authentication, session management, security features). These cannot be disabled.
• Performance Cookies: Collect anonymous data about how visitors use our website (page views, traffic sources, time spent) to help us improve performance.
• Functionality Cookies: Remember your preferences (language, currency, display settings) to provide a personalized experience.
• Marketing Cookies: Track your activity across websites to deliver targeted advertisements and measure campaign effectiveness (used only with your consent).

11.3 Managing Cookies

You can manage cookie preferences through your browser settings. Most browsers allow you to block or delete cookies, although this may affect the functionality of our platform. To learn more about managing cookies, visit your browser's help pages.

12. Changes to This Privacy Policy

atom88 reserves the right to update this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or business operations. When we make material changes, we will notify you by posting a prominent notice on our website or sending an email to your registered email address. The "Last Updated" date at the top of this policy indicates when it was last revised.

Your continued use of the atom88 platform after changes are posted constitutes your acceptance of the updated Privacy Policy. We encourage you to review this policy periodically to stay informed about how we protect your data.

13. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us:

• Email: [email protected]
• Subject Line: "Privacy Inquiry" or "Data Protection Request"
• 24/7 Live Chat: Available through your account dashboard (select "Privacy & Security" topic)

We will respond to all privacy-related inquiries within 30 days. For urgent security concerns (suspected data breach, unauthorized account access), contact us immediately through live chat or phone support.