Privacy Policy

1. Introduction and Scope

thr89 ("we," "our," or "us") is committed to protecting the privacy and personal data of all users of the thr89 online betting platform at https://thr89.cam (the "Platform"). This Privacy Policy explains what information we collect, why we collect it, how we use and protect it, and what rights you have with respect to your personal data.

This Policy applies to all visitors, registered users, and players who interact with the thr89 Platform, website, customer support channels, and related digital services. It applies regardless of the device or method of access — desktop browser, mobile browser, or any future native application.

By using thr89, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal information as described herein. This Policy should be read alongside our Terms & Conditions, which govern your overall use of the Platform.

2. Definitions

For the purpose of this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" means any information that identifies, or could reasonably be used to identify, a living individual — including name, email address, phone number, government ID number, IP address, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, deletion, or any combination thereof.
• "Data Controller" refers to thr89, which determines the purposes and means of processing your Personal Data.
• "Data Processor" refers to any third party that processes Personal Data on behalf of thr89 under a contractual obligation and under our instructions.
• "KYC" (Know Your Customer) refers to the identity verification process we are required to conduct under international anti-money-laundering regulations.
• "Cookies" refers to small text files placed on your device by the Platform to store preferences, session information, and usage analytics.
• "User," "you," "your" refers to any individual accessing or using the thr89 Platform.

3. Information We Collect

3.1 Information You Provide Directly

When you register for an account, complete identity verification, or contact our support team, you provide us with personal information including:

• Account Registration: Full legal name, date of birth, email address, phone number, and residential address (city and province within Indonesia, e.g., Jakarta, Surabaya, Bali).
• KYC Verification Documents: A copy of your Indonesian National Identity Card (KTP) or passport, proof of address (bank statement or utility bill), and selfie verification photographs.
• Financial Information: Bank account details (BCA, BRI, BNI, Mandiri, CIMB Niaga) or e-wallet identifiers (OVO, DANA, GoPay, ShopeePay) used for deposits and withdrawals. We do not store full card numbers or banking credentials.
• Communications: Records of your correspondence with our customer support team, including live chat transcripts, support tickets, and emails sent to [email protected].
• Responsible Gaming Information: Self-exclusion requests, deposit limits, session limits, and self-assessment quiz responses, where voluntarily provided.

3.2 Information Collected Automatically

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

• Device and Access Data: IP address, browser type and version, operating system, device type (mobile or desktop), screen resolution, and referring URL.
• Usage Data: Pages visited, time spent on each page, game sessions played, bets placed, features used, search queries within the Platform, and clickstream data.
• Transaction Logs: Deposit and withdrawal history, bet history, game results, bonus claims, and associated timestamps (in WIB, UTC+7).
• Session Data: Login times, session duration, and logout events, which help us detect unusual account activity.

3.3 Information from Third Parties

We may receive information about you from the following third-party sources:

• Payment Providers: Transaction confirmation data from Indonesian bank transfer services and e-wallet providers (OVO, DANA, GoPay, ShopeePay) to verify deposit and withdrawal processing.
• Identity Verification Services: Third-party KYC and AML screening providers who verify your identity documents and screen against sanctions and politically exposed persons (PEP) databases.
• Fraud Prevention Services: Information from fraud detection vendors to identify suspicious account activity, unusual betting patterns, or potential abuse of promotional offers.
• Analytics Providers: Aggregated, anonymized usage statistics from analytics platforms to understand how users navigate the Platform.

4. How We Use Your Information

thr89 uses the personal information collected for the following specific purposes:

4.1 Account Management and Service Delivery

• Creating and maintaining your thr89 Account.
• Processing deposits and withdrawals via BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, and ShopeePay.
• Settling bets, distributing winnings, and managing bonus credits.
• Providing 24/7 customer support in Indonesian and English.
• Sending account-related notifications (transaction confirmations, security alerts, KYC status updates).

4.2 Legal and Regulatory Compliance

• Conducting KYC identity verification as required by international gaming regulations.
• Performing anti-money-laundering (AML) screening and transaction monitoring.
• Reporting to regulatory authorities as required by our international gaming license obligations.
• Maintaining records for audit purposes for a minimum period as required by law.
• Verifying that users meet the minimum age requirement of 21 years.

4.3 Security and Fraud Prevention

• Detecting, investigating, and preventing fraud, bonus abuse, and unauthorized account access.
• Monitoring for unusual betting patterns, collusion, or use of automated systems (bots).
• Enforcing self-exclusion requests and responsible gaming restrictions.
• Protecting the integrity of games and the fairness of the betting environment.

4.4 Platform Improvement

• Analyzing aggregated usage data to understand how players interact with the Platform.
• Testing and improving game performance, page loading speeds, and mobile experience.
• Personalizing your Platform experience based on your betting history and preferences (for example, surfacing relevant BRI Liga 1 markets or preferred game categories).

4.5 Marketing Communications

With your explicit consent, we may send you promotional emails or notifications about offers, bonuses, and new features on thr89. You may withdraw this consent at any time by clicking the "unsubscribe" link in any marketing email or by contacting our support team. Withdrawing marketing consent does not affect our ability to send you transactional communications related to your Account.

5. Legal Basis for Processing

thr89 processes your personal data on one or more of the following legal grounds:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions you accepted at registration — including operating your Account, processing bets, and facilitating payments.
• Legal Obligation: Processing required to comply with international gaming regulations, AML laws, KYC requirements, and applicable data protection laws.
• Legitimate Interests: Processing necessary for our legitimate business interests, including fraud prevention, platform security, and service improvement, provided those interests do not override your rights and freedoms.
• Consent: Processing based on your freely given consent, specifically for marketing communications. You may withdraw consent at any time without affecting prior processing.

6. Data Sharing and Disclosure

thr89 does not sell or rent your personal data to third parties. We share your data only in the following circumstances:

6.1 Service Providers and Data Processors

We engage carefully vetted third-party service providers who process personal data on our behalf and under our instructions, including: payment processing partners (Indonesian banks and e-wallet operators), KYC and identity verification vendors, fraud detection services, cloud hosting and data storage providers, customer support platform providers, and analytics services. All third-party processors are bound by contractual data processing agreements that prohibit them from using your data for any purpose beyond the specific service they provide to thr89.

6.2 Legal Requirements and Regulatory Disclosure

We may disclose your personal data if required to do so by applicable law, court order, regulatory mandate, or at the request of a government authority with appropriate jurisdiction. We will notify you of such disclosure to the extent legally permitted.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets affecting thr89, your personal data may be transferred as part of that transaction. We will notify you by prominent notice on the Platform or by email before your data is transferred and becomes subject to a different privacy policy.

6.4 Aggregated and Anonymized Data

We may share aggregated, de-identified statistical information about Platform usage (such as total number of bets placed on BRI Liga 1 matches, or most-used payment methods) with business partners or in public reports. Such data cannot be used to identify any individual user.

7. Cookies and Tracking Technologies

thr89 uses cookies and similar tracking technologies to operate and improve the Platform. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in, security tokens, and CSRF protection tokens. These cannot be disabled without breaking core functionality.
• Functional Cookies: Store your preferences such as preferred language (English), currency display (IDR), and game lobby layout to personalize your experience.
• Analytics Cookies: Collect anonymized data about how users navigate the Platform — pages visited, time spent, and click patterns — to help us improve usability and performance.
• Security Cookies: Help detect and prevent fraudulent activity, identify suspicious login attempts, and protect your Account from unauthorized access.

You can manage cookie preferences through your browser settings. Note that disabling functional cookies may affect your Platform experience, while disabling strictly necessary cookies will prevent you from using certain features of the Platform.

8. Data Retention

thr89 retains your personal data for as long as is necessary for the purposes described in this Policy, subject to the following retention guidelines:

• Active Account Data: Retained for the duration of your Account's active status plus a minimum of 5 years after account closure, as required by international gaming regulations and AML compliance obligations.
• Transaction Records: Bet history, deposit and withdrawal logs, and financial transaction records are retained for a minimum of 7 years for regulatory and audit purposes.
• KYC Documents: Identity documents submitted for verification are retained for the period required by the applicable AML regulations of the licensing jurisdiction.
• Customer Support Communications: Live chat transcripts and email records are retained for 3 years from the date of the communication.
• Marketing Consent Records: Records of your marketing consent and any withdrawal of consent are retained for 3 years to demonstrate compliance.

When personal data is no longer required for legitimate purposes, it is securely deleted or anonymized in accordance with our internal data deletion procedures.

9. Your Rights and Choices

Subject to applicable law, you have the following rights with respect to your personal data held by thr89:

• Right of Access: Request a copy of the personal data we hold about you, along with information about how it is processed.
• Right to Rectification: Request correction of inaccurate or incomplete personal data. You may also update most Account details directly through your Account settings.
• Right to Erasure: Request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Restriction of Processing: Request that we limit how we use your data in certain circumstances, for example while a dispute is being resolved.
• Right to Data Portability: Request a structured, machine-readable copy of the personal data you have provided to us, where technically feasible.
• Right to Object: Object to processing of your personal data based on legitimate interests, including profiling for personalized game recommendations.
• Right to Withdraw Consent: Where processing is based on consent (e.g., marketing emails), withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact our Data Protection team at [email protected] with the subject line "Privacy Rights Request." We will respond within 30 days. Note that certain rights may be limited where retention is required for legal compliance, fraud prevention, or regulatory obligations.

10. Data Security Measures

thr89 implements industry-standard technical and organizational security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the Platform.
• AES-256 encryption for sensitive data stored at rest, including KYC documents and financial records.
• Multi-factor authentication (MFA) options for Account login to reduce unauthorized access risk.
• Role-based access controls limiting internal staff access to personal data on a strict need-to-know basis.
• Regular security audits, penetration testing, and vulnerability assessments conducted by independent third parties.
• Dedicated information security teams monitoring for breaches, intrusion attempts, and anomalous data access patterns.

11. International Data Transfers

thr89 may store and process your personal data on servers located outside of Indonesia, in jurisdictions where our hosting infrastructure and key service providers operate. When transferring personal data internationally, we ensure appropriate safeguards are in place, including contractual clauses based on internationally recognized data protection standards and, where applicable, transfers only to jurisdictions with an adequate level of data protection as assessed by relevant regulatory bodies.

12. Children's Privacy

thr89 is strictly an adults-only platform. We do not knowingly collect personal data from individuals under the age of 21. Our registration process requires users to confirm they are 21 or older, and we verify age through the KYC documentation process. If we become aware that we have inadvertently collected personal data from a person under 21, we will immediately delete that data and close the associated Account. If you believe a minor has registered on thr89, please contact us at [email protected] immediately.

13. Changes to This Privacy Policy

thr89 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or regulatory obligations. When we make material changes, we will update the "Last Updated" date at the top of this page and notify registered users via email or a prominent notice on the Platform at least 14 days before the changes take effect. Your continued use of thr89 after the effective date of any modification constitutes your acceptance of the updated Privacy Policy. We encourage you to review this page periodically.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how thr89 handles your personal data, please contact our Data Protection team:

• Email: [email protected]
• Subject Line for Privacy Requests: "Privacy Rights Request" or "Data Protection Inquiry"
• Customer Support: Available 24/7 via live chat on the Platform
• Response Time: We aim to respond to all privacy inquiries within 30 days.