Privacy Policy

1 Introduction

89zk operates as an online sports betting and gaming platform serving Players primarily based in Indonesia. As part of delivering our services — including sports betting markets, live casino games, togel (Indonesia's traditional numbers lottery), and other gaming products — we necessarily collect and process certain personal data about our registered Players.

We take our data protection responsibilities seriously. 89zk implements industry-standard technical and organisational measures to safeguard personal information against unauthorised access, accidental loss, and unlawful processing. This Policy has been drafted to give you full transparency over how your data is handled from the moment you register an account to the point at which your data is permanently deleted.

This Policy should be read alongside our Terms & Conditions, which govern the broader contractual relationship between you and 89zk. In the event of any conflict between this Policy and the Terms & Conditions on a privacy-related matter, this Policy takes precedence.

2 Definitions

3 Data We Collect

89zk collects the following categories of Personal Data in connection with your use of the platform:

3.1 Registration & Identity Data

• Full legal name as it appears on your government-issued identity document
• Date of birth (to verify you meet the 21+ age requirement)
• Nationality and country of residence (Indonesia)
• Email address and mobile phone number
• Username and encrypted password hash

3.2 KYC & Verification Data

• Scanned or photographed copies of your Indonesian National Identity Card (KTP) or valid passport
• Proof of payment method ownership (e.g., photograph of a bank card or screenshot of a registered e-wallet account such as OVO, DANA, GoPay, ShopeePay, or LinkAja)
• Proof of residential address (where requested)
• Selfie photographs submitted for liveness verification

3.3 Financial & Transaction Data

• Bank account details for withdrawal purposes (bank name — BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata — account number, and account holder name)
• Deposit amounts, deposit timestamps, and deposit payment method
• Withdrawal request amounts and processing status
• Bet placement history, including stake amounts, selected markets, and settlement outcomes
• Account balance history and bonus transaction records

3.4 Technical & Device Data

• IP address and geolocation data derived from IP
• Device type, operating system version, and browser type
• Mobile device identifiers (where applicable)
• Session timestamps and session duration data
• Pages visited within the platform and feature interaction logs

3.5 Communications Data

• Records of live chat, WhatsApp, and email communications with the 89zk support team
• Feedback, complaints, and dispute records
• Responses to voluntary satisfaction surveys (where applicable)

3.6 Responsible Gaming Data

• Self-imposed deposit limit settings and change history
• Session time limit settings
• Cooling-off period and self-exclusion requests
• Any health-related information voluntarily provided in connection with a responsible gaming support request (treated as Sensitive Data with heightened protection)

4 How We Collect Data

89zk collects Personal Data through the following channels:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal request, contact support, or respond to a survey.
• Automatically from your device: Through standard web server logs, cookies, and similar tracking technologies when you browse or interact with the 89zk platform. See Section 10 (Cookies & Tracking) for details.
• From payment service providers: When a deposit or withdrawal transaction is confirmed by a third-party payment gateway (such as a bank or e-wallet operator), we receive a transaction confirmation record containing limited financial data.
• From identity verification partners: Where 89zk uses a third-party KYC technology provider to assist with document authentication, that provider returns a verification result to 89zk along with any data necessary for our compliance records.
• From fraud detection and anti-money laundering (AML) tools: Automated risk-scoring systems may process transaction patterns and generate risk flags that form part of a Player's account record.

5 Purposes of Processing

89zk processes your Personal Data for the following purposes:

6 Legal Basis for Processing

89zk processes your Personal Data on the following legal bases:

• Contractual necessity: Processing required to perform our contractual obligations to you under the Terms & Conditions — including account management, bet settl ement, and payment processing.
• Legal obligation: Processing required to comply with applicable legal and regulatory requirements, including KYC/AML obligations and financial record-keeping duties.
• Legitimate interests: Processing carried out to pursue 89zk's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and internal analytics — provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing based on your freely given, specific, informed consent — primarily in the context of direct marketing communications and optional cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7 Data Sharing & Disclosure

89zk does not sell, rent, or trade your Personal Data to any third party for commercial purposes. We share Personal Data only in the following limited and controlled circumstances:

7.1 Service Providers (Data Processors)

89zk engages carefully selected third-party service providers who process Personal Data solely on our behalf and under binding data processing agreements. These include:

• Payment gateway and banking integration partners (including Indonesian banks such as BCA, BRI, BNI, Mandiri, CIMB Niaga, and e-wallet operators such as OVO, DANA, GoPay, ShopeePay, LinkAja)
• KYC and identity verification technology providers
• Cloud infrastructure and hosting providers
• Fraud detection and AML screening services
• Customer support platform providers (live chat and helpdesk software)
• Game content providers (such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft) — limited to session and game-result data necessary for game delivery and bet settlement

7.2 Legal & Regulatory Disclosure

89zk may disclose Personal Data to law enforcement agencies, financial intelligence units, regulatory bodies, or courts of competent jurisdiction where such disclosure is required by applicable law, a valid legal order, or where we have a good-faith belief that disclosure is necessary to prevent fraud, money laundering, or serious harm to any individual.

7.3 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of all or a portion of 89zk's business assets, Personal Data held by 89zk may be transferred to the acquiring entity, subject to the acquiring entity agreeing to honour this Privacy Policy or replacing it with a policy that provides equivalent protections. You will be notified of any such transfer in advance where practicable.

7.4 Aggregated & Anonymised Data

89zk may share aggregated, anonymised data — from which no individual can be identified — with third parties for research, analytics, or business development purposes. Such data does not constitute Personal Data and is not subject to the restrictions of this Policy.

8 International Data Transfers

As an internationally operating online gaming platform, 89zk may transfer certain Personal Data to data processors and infrastructure providers located outside Indonesia. Where such transfers occur, 89zk takes the following steps to ensure your data remains adequately protected:

• Transfers are made only to countries or organisations that provide an adequate level of data protection as assessed by 89zk's data governance review process.
• Where an adequacy determination is not available, 89zk implements contractual safeguards — including standard contractual clauses — between 89zk and the receiving party prior to any transfer.
• All international Data Processors engaged by 89zk are bound by data processing agreements that impose equivalent security and confidentiality obligations as those applied within Indonesia.

9 Data Retention

89zk retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. Our standard retention periods are as follows:

At the end of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised. Where deletion is requested by a Player before the end of a mandatory retention period, 89zk will suppress the data from active use while retaining it in a restricted archive solely for compliance purposes.

10 Cookies & Tracking Technologies

89zk uses cookies and similar tracking technologies to deliver a functional, secure, and personalised experience on the platform. The following categories of cookies are in use:

10.1 Strictly Necessary Cookies

These cookies are essential for the platform to function and cannot be disabled. They include session authentication tokens, security cookies that protect against cross-site request forgery (CSRF), and load-balancing cookies. No consent is required for strictly necessary cookies.

10.2 Functional Cookies

Functional cookies remember your preferences — such as your preferred language setting, last viewed sport category, or live casino table layout — to provide a more personalised experience. These cookies may be disabled, but doing so may affect the quality of your experience on the platform.

10.3 Analytics Cookies

With your consent, 89zk uses first-party analytics tools to collect aggregated data about how Players navigate and interact with the platform. This data is used exclusively for internal product improvement purposes and is not shared with advertising networks. Analytics cookies collect data such as pages visited, time on page, and feature interaction frequency.

10.4 Cookie Management

You may manage your cookie preferences at any time through your browser settings. Disabling cookies via browser settings may affect the functionality of certain platform features. Most modern browsers — including Chrome, Firefox, Safari, and the Android and iOS browsers commonly used by Indonesian Players — provide accessible cookie management options in their Privacy or Settings menus.

11 Your Data Rights

As a registered Player whose Personal Data is processed by 89zk, you hold the following rights in respect of your data:

• Right of Access: You may request a copy of the Personal Data that 89zk holds about you, together with information about how it is being used. 89zk will respond to access requests within 30 calendar days.
• Right to Rectification: If any Personal Data held by 89zk about you is inaccurate or incomplete, you have the right to request that it be corrected or supplemented. Minor updates — such as changes to your registered email address or phone number — may be made directly within your account settings.
• Right to Erasure ("Right to be Forgotten"): You may request the deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where processing is unlawful. Note that 89zk may be required to retain certain data beyond your erasure request to comply with legal retention obligations (see Section 9).
• Right to Restriction of Processing: You may request that 89zk restrict the processing of your Personal Data in certain circumstances — for example, while a rectification request is under review, or where you contest the legal basis for processing.
• Right to Data Portability: Where processing is based on consent or contractual necessity and carried out by automated means, you have the right to receive your Personal Data in a structured, commonly used, machine-readable format, and to request that it be transmitted directly to another service provider where technically feasible.
• Right to Object: You may object to the processing of your Personal Data where that processing is based on 89zk's legitimate interests. 89zk will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• Right to Withdraw Consent: Where processing is based solely on your consent, you may withdraw that consent at any time without detriment. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

To exercise any of these rights, please submit a written request to [email protected]. We may be required to verify your identity before processing any data rights request. 89zk will respond to all verified requests within 30 calendar days; in complex cases, this period may be extended by a further 60 days, with notification provided to you.

12 Children's Privacy

The 89zk platform is strictly intended for adults aged 21 years and over. 89zk does not knowingly collect, process, or retain Personal Data belonging to individuals under the age of 21. If we discover or are notified that a registered Player is under 21 years of age, the following actions will be taken immediately:

• The account will be suspended and access to the platform disabled.
• All Personal Data associated with the underage account will be securely deleted, except where retention is required for legal compliance or fraud investigation purposes.
• Any funds deposited by the underage Player will be refunded to the verified source payment method where practicable, after deducting any amounts legally forfeited under the Terms & Conditions.

13 Security Measures

89zk implements a layered security architecture to protect your Personal Data against unauthorised access, disclosure, alteration, and destruction. Our current security measures include:

• Encryption in transit: All data exchanged between your browser or device and the 89zk platform is encrypted using TLS 1.2 or TLS 1.3 with 256-bit encryption. The platform enforces HTTPS across all endpoints.
• Encryption at rest: Sensitive Personal Data — including KYC documents, financial account details, and password hashes — is stored using AES-256 encryption at rest on our infrastructure.
• Access controls: Internal access to Personal Data is governed by a role-based access control (RBAC) policy. Only authorised personnel with a documented business need may access Player Personal Data, and all access events are logged and periodically audited.
• Password security: Player passwords are never stored in plain text. Passwords are stored as salted cryptographic hashes using a current industry-standard hashing algorithm.
• Fraud detection systems: Automated systems monitor account activity in real time to detect anomalous patterns indicative of account compromise, unauthorised access, or financial fraud.
• Penetration testing: 89zk's platform undergoes periodic security assessments conducted by independent security professionals to identify and remediate vulnerabilities.
• Incident response: In the event of a confirmed data breach affecting your Personal Data, 89zk will notify affected Players without undue delay, describe the nature of the breach, and outline the steps taken to mitigate harm.

While 89zk takes comprehensive steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your own account credentials and should notify us immediately if you suspect unauthorised access to your account.

14 Third-Party Links & Services

The 89zk platform may contain references to third-party services — such as game studios, payment providers, or sports data feeds — that operate under their own independent privacy policies. 89zk has no control over and bears no responsibility for the data collection and processing practices of third-party services accessed in connection with your use of the platform.

We encourage you to review the privacy policies of any third-party providers whose services you interact with. The inclusion of a third-party provider's services on the 89zk platform does not constitute an endorsement of that provider's privacy practices.

15 Policy Amendments

89zk reserves the right to update or amend this Privacy Policy at any time. Where a change is material — meaning it alters your rights, expands the categories of data collected, introduces new purposes for processing, or changes the basis on which data is shared — 89zk will provide at least fourteen (14) days' advance notice by displaying a prominent notice on the platform and, where possible, by sending a notification to your registered email address.

Minor amendments — such as clarifications of existing language, corrections of typographical errors, or updates to contact details — may be made without advance notice. The "Last Updated" date at the top of this page will always reflect the most recent revision date. We encourage you to review this Policy periodically to stay informed of how your Personal Data is being protected.

Your continued use of the 89zk platform following the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree with the amended Policy, you must cease using the platform and request account closure before the effective date.

16 Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way in which 89zk handles your Personal Data, please contact us through the following channels:

If you believe that 89zk has failed to adequately address your privacy concern, you retain the right to escalate your complaint to the relevant data protection authority or supervisory body in your jurisdiction. 89zk commits to cooperating fully with any legitimate regulatory investigation into our data practices.