Privacy Policy

1. Introduction

This Privacy Policy ("Policy") applies to all personal information collected by seru69 ("the Company", "we", "us", "our") through the website https://seru69.cam ("the Platform") and any associated mobile applications, customer support channels, or other services we provide.

This Policy should be read in conjunction with our Terms & Conditions, which govern your use of the Platform. By registering an account or using any service on the Platform, you confirm that you have read, understood, and agree to this Privacy Policy.

If you do not agree with any aspect of this Policy, you must immediately cease using the Platform and contact us to close your account.

2. Data Controller

seru69 acts as the data controller for all personal information collected through the Platform. This means we determine the purposes and means of processing your personal data and are responsible for ensuring compliance with applicable data protection laws.

For any questions or concerns regarding this Privacy Policy or your personal data, you may contact our Data Protection Officer at:

• Email: [email protected]
• Subject Line: "Privacy Inquiry" or "Data Protection Request"

3. Information We Collect

seru69 collects various types of personal information to provide, maintain, and improve our services. The information we collect falls into the following categories:

3.1 Information You Provide Directly

When you register an account, verify your identity, or interact with our support team, you provide us with:

• Identity Information: Full legal name (as it appears on your KTP or passport), date of birth, gender, nationality, and residential address.
• Contact Information: Email address, Indonesian mobile phone number, and preferred contact method.
• Financial Information: Bank account details (account holder name, bank name, account number) for Indonesian banks including BCA, BRI, BNI, Mandiri, CIMB Niaga, and Bank Permata; e-wallet account details for OVO, DANA, GoPay, ShopeePay, and LinkAja.
• Identity Verification Documents: Clear photographs or scans of your Indonesian KTP or valid passport, selfie photographs holding your identity document, and proof of payment method ownership where required for enhanced due diligence.
• Communications: Any information you provide when contacting customer support via email, live chat, WhatsApp, or other communication channels, including the content of your messages and attached files.

3.2 Information Collected Automatically

When you access or use the Platform, we automatically collect certain technical and usage information:

• Device Information: IP address, device type and model, operating system and version, browser type and version, screen resolution, and unique device identifiers.
• Usage Data: Pages visited, features accessed, games played, bet history, deposit and withdrawal transactions, session duration, click patterns, and referral sources.
• Location Data: Approximate geographic location based on IP address to ensure compliance with territorial restrictions and provide localized content.
• Cookies and Similar Technologies: Small text files and tracking pixels stored on your device to recognize you, remember your preferences, analyze Platform usage, and deliver personalized content. See Section 8 for detailed information on cookies.

3.3 Information from Third Parties

In limited circumstances, we may receive personal information about you from third-party sources:

• Payment Processors: Transaction confirmation data from Indonesian banks and e-wallet providers to verify deposits and process withdrawals.
• Identity Verification Services: Age and identity validation results from third-party KYC providers where applicable.
• Fraud Prevention Services: Risk scores and device fingerprinting data from specialized anti-fraud platforms to protect Member accounts and detect suspicious activity.

4. How We Use Your Data

seru69 processes your personal information for the following purposes, each of which is necessary to provide you with a secure and enjoyable gaming experience:

4.1 Account Management

• Creating and maintaining your seru69 Account
• Authenticating your identity when you log in
• Managing your account settings, preferences, and responsible gaming limits
• Providing customer support and responding to your inquiries

4.2 Service Delivery

• Processing deposits, withdrawals, and other financial transactions
• Providing access to casino games, sports betting, live dealer tables, and other gaming products
• Recording and settling bets, calculating winnings, and updating account balances
• Delivering promotional bonuses, free spins, and other rewards you are eligible to receive

4.3 Compliance and Security

• Verifying that you are at least 21 years of age and a resident of Indonesia
• Conducting Know Your Customer (KYC) and anti-money laundering (AML) checks as required by international gaming regulations
• Detecting, preventing, and investigating fraud, collusion, bonus abuse, and other prohibited conduct
• Monitoring account activity for security threats and unauthorized access attempts
• Complying with legal obligations, court orders, and requests from law enforcement or regulatory authorities

4.4 Platform Improvement

• Analyzing usage patterns to understand how Members interact with the Platform
• Identifying technical issues, optimizing performance, and fixing bugs
• Developing new features, games, and services based on Member feedback and behavior
• Conducting market research and statistical analysis to improve our offerings

4.5 Marketing and Communications

• Sending you important service notifications regarding account activity, withdrawals, bonus credits, and policy updates
• With your consent, sending promotional emails, SMS messages, or push notifications about new games, special offers, and exclusive tournaments
• Personalizing marketing content based on your gaming preferences and activity history

Note: You may opt out of promotional communications at any time by adjusting your account preferences or clicking the "unsubscribe" link in any marketing email. Service-related notifications (e.g., withdrawal confirmations, security alerts) cannot be opted out of as they are essential to platform operation.

5. Legal Basis for Processing

Under data protection law, seru69 must have a valid legal basis to process your personal information. We rely on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contract with you (the Terms & Conditions) and provide the services you have requested, including account creation, transaction processing, and game access.
• Legal Obligation: Processing is required to comply with legal obligations such as age verification, KYC/AML regulations, tax reporting, and responses to lawful requests from authorities.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security monitoring, platform improvement, and customer support, provided these interests do not override your fundamental rights and freedoms.
• Consent: Where required by law (e.g., for marketing communications or non-essential cookies), we obtain your explicit consent before processing certain types of data. You may withdraw consent at any time through your account settings.

6. Data Sharing and Disclosure

seru69 does not sell, rent, or trade your personal information to third parties for their own marketing purposes. We may, however, share your data with carefully selected third parties in the following limited circumstances:

6.1 Service Providers

We engage trusted third-party companies to perform services on our behalf, including:

• Payment Processors: Indonesian banks, e-wallet providers, and payment gateway operators who facilitate deposits and withdrawals.
• Game Studios: Software providers such as Pragmatic Play, Evolution Gaming, NetEnt, and Microgaming who supply casino games and live dealer tables.
• KYC/AML Vendors: Identity verification and document authentication services that assist with compliance checks.
• Cloud Hosting Providers: Secure data center operators who host our servers and databases.
• Customer Support Tools: Live chat platforms, email management systems, and CRM software used to deliver support services.

All service providers are contractually bound to process your data only for specified purposes, maintain confidentiality, and implement appropriate security measures. They are prohibited from using your data for their own purposes.

6.2 Legal and Regulatory Authorities

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

• Required by applicable law, regulation, or legal process (e.g., court order, subpoena)
• Necessary to investigate suspected illegal activity, fraud, or threats to public safety
• Requested by gaming regulators as part of license compliance audits
• Required to protect the rights, property, or safety of seru69, our Members, or the public

6.3 Business Transfers

In the event that seru69 undergoes a merger, acquisition, asset sale, or other corporate restructuring, your personal information may be transferred to the acquiring entity as part of the transaction. You will be notified via email and a prominent notice on the Platform before any such transfer, and the acquiring entity will be required to continue honoring this Privacy Policy.

6.4 Aggregated and Anonymized Data

We may share aggregated, de-identified, or anonymized data that cannot reasonably be used to identify you with third parties for analytical, research, or marketing purposes. For example, we might share statistics on overall player activity, popular games, or regional trends without revealing individual Member information.

7. Data Security Measures

seru69 employs industry-leading technical and organizational measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

7.1 Technical Safeguards

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS protocols. Sensitive data at rest (including passwords and KYC documents) is encrypted using AES-256 or equivalent standards.
• Password Security: Passwords are hashed using bcrypt or similar one-way cryptographic algorithms and are never stored in plain text. We enforce strong password requirements and encourage Members to use unique passwords for their seru69 account.
• Firewalls and Intrusion Detection: Our servers are protected by enterprise-grade firewalls, intrusion detection systems (IDS), and real-time threat monitoring to block unauthorized access attempts.
• Regular Security Audits: We conduct periodic security assessments, vulnerability scans, and penetration testing performed by independent third-party security firms.

7.2 Organizational Safeguards

• Access Controls: Personal data is accessible only to authorized personnel who require it to perform their job functions. Access is granted on a need-to-know basis and is regularly reviewed.
• Employee Training: All staff members receive mandatory training on data protection principles, security best practices, and seru69's internal privacy policies.
• Confidentiality Agreements: Employees, contractors, and service providers sign legally binding confidentiality agreements prohibiting unauthorized disclosure of Member data.
• Incident Response: We maintain a comprehensive data breach response plan. In the unlikely event of a security incident affecting your personal information, we will notify you and relevant authorities in accordance with applicable law.

8. Cookies and Tracking Technologies

seru69 uses cookies, web beacons, and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver personalized content.

8.1 What Are Cookies?

Cookies are small text files stored on your device by your web browser. They allow the Platform to remember your preferences, recognize you when you return, and track your interactions across pages.

8.2 Types of Cookies We Use

• Essential Cookies: Required for basic Platform functionality, including login authentication, session management, and security. These cannot be disabled without preventing you from using core features.
• Performance Cookies: Collect anonymous data on how visitors use the Platform (e.g., most-visited pages, error messages) to help us improve performance and user experience.
• Functional Cookies: Remember your preferences (e.g., language selection, favorite games) to provide enhanced, personalized features.
• Targeting/Advertising Cookies: Track your activity across the Platform and external sites to deliver relevant promotional content and measure advertising campaign effectiveness.

8.3 Managing Cookies

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies or alert you when a cookie is being set. Please note that disabling cookies may limit your ability to use certain Platform features.

To learn more about managing cookies, visit your browser's help documentation or allaboutcookies.org.

9. Your Privacy Rights

seru69 respects your rights regarding your personal information. Depending on your location and applicable data protection laws, you may have the following rights:

9.1 Right of Access

You have the right to request confirmation of what personal information we hold about you and obtain a copy of that data in a structured, commonly used, and machine-readable format.

9.2 Right to Rectification

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

9.3 Right to Erasure ("Right to Be Forgotten")

You may request that we delete your personal information under certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, or if you withdraw consent where that was the legal basis for processing. Note that we may be required to retain certain data for legal or regulatory compliance purposes even after you request deletion.

9.4 Right to Restrict Processing

You may request that we temporarily restrict the processing of your personal data in specific situations, such as while we investigate a dispute regarding data accuracy or the lawfulness of processing.

9.5 Right to Data Portability

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

9.6 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 through your account settings.

9.7 Right to Withdraw Consent

Where processing is based on your consent (e.g., marketing communications), you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing that occurred before withdrawal.

9.8 How to Exercise Your Rights

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with the subject line "Privacy Rights Request" and include your full name, registered email address, and a description of the right you wish to exercise. We will respond to your request within 30 days.

10. Children's Privacy

seru69 is an adult-only platform. We do not knowingly collect personal information from, or market to, individuals under the age of 21. All Members must be at least 21 years of age and provide proof of age through our KYC verification process before any withdrawal can be processed.

If we become aware that we have inadvertently collected personal information from someone under 21, we will immediately suspend the account, delete the data, and return any deposited funds to the original payment method.

Parents and guardians who believe their child may have provided personal information to seru69 should contact us immediately at [email protected] so we can take appropriate action.

11. Data Retention

seru69 retains your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements.

11.1 Active Accounts

While your account remains active, we retain all personal information, transaction history, and usage data to provide ongoing services and support.

11.2 Closed Accounts

After you close your account, we retain certain personal and financial data for a period of 7 years to comply with anti-money laundering regulations, tax reporting requirements, and to defend against potential legal claims. After this retention period expires, your data is securely deleted or anonymized.

11.3 Specific Retention Periods

• KYC Documents: Retained for 7 years after account closure or the end of the business relationship.
• Transaction Records: Retained for 7 years to comply with financial record-keeping obligations.
• Marketing Consent Records: Retained until consent is withdrawn, plus an additional 3 years to demonstrate compliance with marketing regulations.
• Technical Logs: Retained for 90 days for security monitoring and troubleshooting purposes, then deleted unless required for ongoing investigations.

12. International Data Transfers

seru69 operates internationally and may transfer your personal information to servers located outside Indonesia for processing and storage. This may include transfers to countries that do not provide the same level of data protection as Indonesian law.

When we transfer data internationally, we implement appropriate safeguards to protect your information, including:

• Standard Contractual Clauses approved by data protection authorities
• Ensuring service providers are certified under recognized data protection frameworks
• Conducting due diligence on the data protection practices of recipient countries and entities

By using the seru69 Platform, you acknowledge and consent to the international transfer of your personal information as described in this Policy.

13. Changes to This Privacy Policy

seru69 reserves the right to amend or update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. All changes will be published on this page with a revised "Last Updated" date at the top of the document.

Material changes that significantly affect your privacy rights will be communicated via email to all registered Members and displayed as a prominent notification when you log in to your account. Continued use of the Platform after such changes constitutes your acceptance of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information.

14. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy, our data practices, or how your personal information is handled, please contact us through any of the following channels:

• Email: [email protected] (for general privacy inquiries) or [email protected] (for formal data protection requests)
• Subject Line: Use "Privacy Inquiry" for general questions or "Data Protection Request" for formal rights requests (access, deletion, rectification)
• Live Chat: Available 24/7 through the Platform for immediate assistance with privacy-related questions
• WhatsApp Support: Available 24/7 (contact details provided on the Platform)

Our Data Protection Officer and support team will respond to all privacy inquiries within 2 business days for general questions and within 30 days for formal data subject rights requests as required by applicable law.