Privacy Policy

1. Introduction

soju67 ("we," "us," "our") operates the online betting platform accessible at soju67.cam (the "Platform"). We are committed to protecting and respecting the privacy of every individual who interacts with us, whether as a registered player, a visitor browsing the site, or a customer contacting our support team.

This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. It applies to all users of the Platform, with particular relevance to players based in Indonesia — our primary market. The Policy is written in English, consistent with the international-standard approach we apply across all our services.

This Policy should be read in conjunction with our Terms & Conditions, which govern the overall use of the soju67 Platform, and our Responsible Gaming guidelines.

2. Definitions

• "Personal Data" means any information that identifies or could reasonably be used to identify a living individual, directly or indirectly (e.g., full name, national identity number, email address, IP address).
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, erasure, or destruction.
• "Data Controller" refers to soju67, the entity that determines the purposes and means of Processing Personal Data.
• "Data Subject" refers to any identified or identifiable natural person whose Personal Data is Processed by soju67 — in practice, You.
• "Third Party" means any entity other than You and soju67, including payment processors, game providers, analytics services, and regulatory bodies.
• "KYC" means Know Your Customer — the identity verification process required to comply with anti-money laundering obligations.
• "Cookies" means small data files placed on your device by the Platform to facilitate functionality, analytics, and personalized experiences.

3. Personal Data We Collect

We collect and process the following categories of Personal Data, depending on how you interact with the Platform:

Category	Examples	Purpose
Identity Data	Full legal name, date of birth, nationality, government-issued ID (KTP, passport)	Account registration, KYC verification, age verification
Contact Data	Email address, mobile phone number, residential address	Account communication, support, transaction notifications
Financial Data	Bank account details (BCA, BRI, BNI, Mandiri, CIMB Niaga), e-wallet IDs (GoPay, OVO, DANA, ShopeePay), transaction history	Processing deposits, withdrawals, fraud prevention
Activity Data	Bets placed, games played, session duration, win/loss history	Account management, responsible gaming monitoring, analytics
Technical Data	IP address, device type, browser, operating system, geolocation	Platform security, fraud detection, service optimization
Communication Data	Live chat transcripts, email correspondence, support ticket content	Customer support quality assurance, dispute resolution
Marketing Preferences	Opted-in promotional channels, game type preferences	Sending relevant promotions and offers with your consent

4. How We Collect Your Data

4.1 Directly from You

We collect Personal Data that you provide voluntarily when you register an account, complete KYC verification, make a deposit or withdrawal, contact our customer support team, or respond to a survey or promotion.

4.2 Automatically

When you access or use the Platform, we automatically collect Technical Data through server logs, cookies, pixel tags, and similar tracking technologies. This includes your IP address, session timestamps, pages visited, and click-stream data. This data is essential for maintaining platform security, detecting fraud, and improving the overall user experience.

4.3 From Third Parties

We may receive Personal Data about you from third parties where permitted by law. This includes identity verification agencies (for KYC compliance), payment processors (for transaction validation), fraud-prevention services, and analytics providers. We verify that any third-party data source processes your information in accordance with applicable privacy regulations before sharing it with us.

5. Legal Basis for Processing

We process your Personal Data only where we have a valid legal basis to do so. The applicable bases are:

• Contractual Necessity: Processing required to perform the contract between you and soju67 — including account management, bet settlement, and payment processing.
• Legal Obligation: Processing required to comply with applicable anti-money laundering laws, financial regulations, and identity verification requirements.
• Legitimate Interests: Processing for fraud prevention, platform security, analytics, and service improvement — provided these interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for direct marketing communications and non-essential cookies — where you have given clear, informed, and freely withdrawable consent. You may withdraw consent at any time without affecting the legality of prior processing.

6. How We Use Your Personal Data

soju67 uses your Personal Data for the following purposes:

• To create, manage, and authenticate your account, and to verify your identity and age (21+) through KYC procedures.
• To process deposits and withdrawals via Indonesian bank transfers and e-wallets, and to maintain accurate transaction records in IDR.
• To settle bets, calculate winnings, apply bonus credits, and manage your account balance.
• To send transactional communications — including deposit confirmations, withdrawal notifications, account security alerts, and important policy updates.
• To provide customer support, investigate disputes, and maintain records of support interactions.
• To monitor betting activity and enforce responsible gaming limits, including deposit caps, loss limits, and self-exclusion agreements.
• To detect, prevent, and investigate fraud, money laundering, account abuse, and other illegal activities.
• To analyze Platform usage patterns and improve the quality, security, and personalization of our services.
• To send marketing communications about relevant promotions, bonuses, and new features — only where you have opted in to receive such communications.
• To comply with our legal obligations, respond to regulatory inquiries, and enforce our Terms & Conditions.

7. Data Sharing and Disclosure

7.1 Service Providers

We engage trusted third-party service providers who process Personal Data on our behalf under data processing agreements. These include payment processors (facilitating IDR transactions through BCA, BRI, BNI, Mandiri, GoPay, OVO, DANA, ShopeePay, and others), KYC and identity verification providers, game software providers (e.g., Evolution Gaming, Pragmatic Play, NetEnt), fraud-prevention platforms, cloud hosting providers, and customer support software vendors.

7.2 Legal and Regulatory Disclosure

We may disclose Personal Data to governmental authorities, law enforcement agencies, financial intelligence units, or regulatory bodies where we are required to do so by applicable law, court order, or regulatory directive — and only to the extent strictly necessary for compliance.

7.3 Business Transfers

In the event of a merger, acquisition, asset sale, or corporate restructuring involving soju67, your Personal Data may be transferred to the successor entity. We will provide reasonable prior notice where possible, and any successor entity will be required to honor this Privacy Policy or provide you with a materially equivalent level of protection.

7.4 What We Do Not Do

soju67 does not sell, rent, or trade your Personal Data to unaffiliated third parties for their own marketing purposes. We do not share your data with advertisers or data brokers. We do not use your data to build profiles for sale to external parties.

8. Data Retention

We retain your Personal Data for as long as necessary to fulfill the purposes described in this Policy, or as required by applicable law. The following general retention principles apply:

• Active account data is retained for the duration of your account's active status plus a minimum of 5 years following account closure, to comply with financial record-keeping obligations.
• Transaction records are retained for a minimum of 5 years from the date of each transaction, consistent with anti-money laundering regulations.
• KYC documentation is retained for a minimum of 5 years after the end of the business relationship, as required by applicable regulations.
• Marketing consent records are retained for as long as you remain opted in, plus 2 years thereafter for audit purposes.
• Support interaction records are retained for 2 years from the date of resolution.

When data is no longer required, it is securely deleted or anonymized in accordance with our data disposal procedures.

9. Security Measures

soju67 employs industry-standard technical and organizational security measures to protect your Personal Data against unauthorized access, alteration, disclosure, or destruction. Our security framework includes:

• 128-bit SSL/TLS Encryption: All data transmitted between your device and our Platform is encrypted using SSL/TLS protocols.
• Data Encryption at Rest: Sensitive data including financial records and identity documents is encrypted in storage.
• Access Controls: Internal access to Personal Data is restricted on a strict need-to-know basis, with role-based access controls and multi-factor authentication for staff systems.
• Regular Security Audits: We conduct periodic security assessments, penetration tests, and vulnerability scans to identify and address potential weaknesses.
• Fraud Detection Systems: Automated systems monitor for suspicious account activity, unusual transaction patterns, and potential account compromises in real time.
• Incident Response: We maintain a documented incident respons e plan. In the event of a data breach that poses a material risk to your rights and freedoms, we will notify affected users promptly and take immediate remediation steps.

While we take every reasonable precaution to safeguard your data, no internet-based platform can guarantee absolute security. You are responsible for keeping your account credentials confidential and for notifying us immediately at [email protected] if you suspect any unauthorized access to your account.

10. Cookies & Tracking Technologies

10.1 What Are Cookies?

Cookies are small text files placed on your device by the Platform when you visit or use our services. They allow the Platform to recognize your device, remember your preferences, and deliver a more consistent and personalized experience across sessions.

10.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for core Platform functionality, including session authentication, account security, and payment processing. These cannot be disabled without breaking core services.
• Performance & Analytics Cookies: Collect anonymous usage data (pages visited, session duration, error reports) to help us improve Platform performance. No personally identifying information is collected via these cookies.
• Functional Cookies: Remember your preferences such as language settings, preferred payment method, and display options to enhance your experience on return visits.
• Marketing Cookies: Used — with your consent only — to deliver relevant promotional content based on your activity on the Platform. You may opt out of marketing cookies at any time via your account settings.

10.3 Managing Cookies

You may control cookie preferences through your browser settings or your soju67 account preferences page. Note that disabling strictly necessary cookies will impair your ability to use certain Platform features, including account login and payment processing. Disabling analytics or marketing cookies will not affect your ability to place bets or access games.

11. Your Data Rights

As a user of the soju67 Platform, you have the following rights with respect to your Personal Data. To exercise any of these rights, please contact us at [email protected] with the subject line "Data Rights Request." We will respond within 30 days of receiving your request.

• Right of Access: You have the right to request a copy of the Personal Data we hold about you, along with information about how it is processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete Personal Data we hold about you.
• Right to Erasure: You may request deletion of your Personal Data where it is no longer necessary for the purposes it was collected, subject to our legal retention obligations. Note that certain data cannot be erased while an account remains open or while regulatory retention periods apply.
• Right to Restrict Processing: You may request that we temporarily suspend processing of your data in certain circumstances — for example, while the accuracy of the data is being contested.
• Right to Data Portability: You may request a structured, machine-readable copy of the Personal Data you have provided to us, where processing is based on consent or contractual necessity.
• Right to Object: You have the right to object to processing based on legitimate interests, including direct marketing. We will cease processing for that purpose unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based solely on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

12. Minors and Age Restriction

The soju67 Platform is strictly for individuals aged 21 years and above. We do not knowingly collect, process, or store Personal Data relating to individuals under 21 years of age. If you are under 21, you must not use this Platform or provide us with any personal information.

If we become aware that we have inadvertently collected Personal Data from an individual under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the Platform, please contact us immediately at [email protected].

13. Changes to This Privacy Policy

soju67 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform services. When material changes are made, we will update the "Last Updated" date at the top of this page. For significant changes, we may also notify you directly via your registered email address.

Your continued use of the Platform following publication of any updated Policy constitutes your acceptance of the revised terms. We encourage you to review this page periodically to stay informed about how we protect your data.

14. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or our data practices, please reach out to our Data Privacy team:

• Email: [email protected]
• Subject Line: Privacy Policy Inquiry
• Operating Hours: 24/7, Western Indonesia Time (WIB, UTC+7)

We are committed to resolving all privacy-related queries fairly and promptly. If you are not satisfied with our response, you have the right to escalate your concern to the relevant data protection authority in your jurisdiction.