Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how ave189 ("we", "us", or "our") collects, uses, stores, shares, and protects personal information provided by Players ("you" or "your") who register an Account, access the Website at https://ave189.cam, or use any Service offered by ave189.

By creating an Account or using our Services, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with any part of this Policy, please discontinue use of our platform and contact us to request Account closure.

This Policy applies to all personal data collected through:

• The ave189 Website and any associated mobile-optimized pages
• Customer support interactions via live chat, email, or messaging applications
• Account registration and KYC (Know Your Customer) verification processes
• Payment transactions processed through our integrated banking and e-wallet partners
• Cookies, tracking pixels, and similar technologies deployed on the Website

2. Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, date of birth, national identity number, address, email, phone number, financial account details, and IP address.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, transmission, disclosure, alteration, or deletion.
• "Data Controller" refers to ave189, the entity that determines the purposes and means of processing your Personal Data.
• "Third Party" means any person or organization other than you and ave189 involved in the processing of your Personal Data, such as payment processors, identity verification providers, and game software suppliers.
• "Cookies" means small text files placed on your device by the Website to facilitate navigation, remember preferences, and support analytics.

3. Personal Data We Collect

3.1 Data You Provide Directly

When you register an Account, verify your identity, or interact with our platform, you provide us with the following categories of personal data:

Category	Examples	Purpose
Identity Data	Full name, date of birth, national ID (KTP), passport number	Account registration, KYC verification, age compliance
Contact Data	Email address, mobile phone number, residential address	Account communication, support, transaction alerts
Financial Data	Bank account numbers (BCA, BRI, BNI, Mandiri, etc.), e-wallet IDs (OVO, DANA, GoPay), transaction history	Processing deposits and withdrawals, fraud prevention
Verification Data	KTP scan, selfie photograph, proof of address documents	KYC compliance, identity fraud prevention
Support Data	Chat transcripts, email correspondence, support ticket content	Customer service, dispute resolution, quality assurance

3.2 Data Collected Automatically

When you access our Website, we automatically collect certain technical and behavioral data:

• Device and Technical Data: IP address, browser type and version, operating system, device model, screen resolution, and time zone setting.
• Usage Data: Pages visited, links clicked, session duration, game titles accessed, betting history, and login timestamps.
• Location Data: Approximate geographic location derived from your IP address (country and city level — we do not collect precise GPS coordinates).
• Cookie Data: Session identifiers, preference settings, and analytics data as described in Section 8 of this Policy.

3.3 Data We Do Not Collect

ave189 does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data beyond that required for KYC verification, or health and medical information unless voluntarily disclosed by you in the context of a responsible gaming request.

4. Legal Basis for Processing

ave189 processes your personal data on the following legal grounds:

• Contractual Necessity: Processing required to create and manage your Account, process transactions, settle bets, and deliver our Services as described in our Terms and Conditions.
• Legal Obligation: Processing required to comply with anti-money laundering regulations, KYC obligations, age verification requirements, and fraud prevention duties under applicable law.
• Legitimate Interest: Processing carried out to maintain platform security, prevent fraud, improve our Services, and communicate relevant updates, where these interests are not overridden by your rights.
• Consent: Processing for marketing communications, non-essential cookies, and personalized promotions, where you have given explicit prior consent. You may withdraw consent at any time.

5. How We Use Your Personal Data

ave189 uses your personal data strictly for the purposes outlined at the time of collection. Specifically, we use your data to:

• Create, administer, and maintain your Account and deliver the Services you request
• Process deposits and withdrawals via BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, LinkAja, and other supported payment providers
• Verify your identity and age (21+ requirement) in compliance with our KYC policy
• Detect, prevent, and investigate fraud, money laundering, and other illegal activities
• Enforce our Terms and Conditions and other policies
• Provide customer support and resolve disputes
• Send transactional notifications, security alerts, and account-related communications
• Personalize your gaming experience and deliver relevant promotional offers (where you have consented)
• Analyze platform performance, improve product features, and conduct internal research
• Comply with applicable legal obligations and respond to lawful requests from authorities

6. Disclosure of Personal Data to Third Parties

6.1 Service Providers

We engage trusted third-party service providers who process personal data on our behalf, under strict data processing agreements, solely to perform services for ave189. These providers include:

• Payment Processors: Banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to facilitate financial transactions.
• Identity Verification Providers: Third-party KYC and anti-fraud service providers to verify identity documents and screen against sanctions lists.
• Game Software Providers: Licensed gaming studios (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, Pocket Games Soft) that may process gameplay data to operate their games on our platform.
• IT and Security Providers: Cloud hosting, content delivery network (CDN), and cybersecurity providers who maintain the technical infrastructure of our platform.
• Analytics Providers: Web analytics services that help us understand how Players use our platform (data is aggregated and anonymized wherever possible).

6.2 Legal and Regulatory Disclosure

ave189 may disclose your personal data to government authorities, law enforcement agencies, or regulators where required by law, court order, or valid regulatory request. We will notify you of such disclosures where we are legally permitted to do so.

6.3 Business Transfers

In the event of a merger, acquisition, asset sale, or corporate restructuring involving ave189, your personal data may be transferred to the successor entity. You will be notified of any such transfer and the privacy terms applicable to your data under the new ownership.

7. Data Retention

ave189 retains your personal data only for as long as necessary to fulfill the purposes described in this Policy, or as required by applicable law. Our standard retention periods are:

Data Category	Retention Period	Basis
Account and identity records	5 years after Account closure	AML and KYC regulatory obligations
Financial transaction records	5 years from transaction date	Tax and financial reporting obligations
Customer support communications	3 years after resolution	Dispute resolution and quality assurance
Cookie and analytics data	Up to 24 months from collection	Platform improvement and personalization
Marketing consent records	Duration of consent plus 2 years	Evidence of consent, legal compliance

Once the applicable retention period expires, personal data is securely deleted or anonymized so it can no longer be associated with you as an individual.

8. Cookies and Tracking Technologies

8.1 Types of Cookies We Use

ave189 uses the following categories of cookies on our Website:

• Strictly Necessary Cookies: Essential for the Website to function. These include session authentication cookies, security tokens, and load balancing cookies. These cannot be disabled without breaking core functionality.
• Functional Cookies: Remember your preferences such as language settings, preferred payment method, and display options, so you do not need to reconfigure them on each visit.
• Analytics Cookies: Collect aggregated information about how Players navigate the Website, which pages are most visited, and how long sessions last. This data helps us improve usability and performance.
• Marketing Cookies: Used (only with your consent) to deliver relevant promotional content based on your interests and browsing history on our platform.

8.2 Managing Cookie Preferences

You may control cookie preferences through your browser settings at any time. Disabling certain cookies may affect the functionality of the Website. Strictly necessary cookies cannot be disabled through browser settings, as they are essential for platform security and operation.

9. Data Security

ave189 implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security framework includes:

• 256-Bit SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using industry-standard TLS 1.2 or higher protocols.
• Data Encryption at Rest: Sensitive personal data stored in our databases is encrypted at rest using AES-256 encryption.
• Access Controls: Personal data access is restricted on a strict need-to-know basis. All employee access is logged, monitored, and subject to regular audit.
• Two-Factor Authentication: Internal systems storing personal data require multi-factor authentication for all staff access.
• Penetration Testing: Regular third-party security audits and penetration tests are conducted to identify and remediate vulnerabilities.
• Incident Response: We maintain a documented data breach response plan. In the event of a breach affecting your rights and freedoms, we will notify you and relevant authorities without undue delay as required by applicable regulations.

10. Your Rights and Choices

As a Player on the ave189 platform, you have the following rights regarding your personal data:

To exercise any of these rights, please contact our Data Protection team via email at [email protected]. We will respond to all valid requests within 30 calendar days. We may need to verify your identity before processing any data rights request.

11. International Data Transfers

ave189 operates an internationally distributed infrastructure, which means your personal data may be transferred to and processed in countries outside Indonesia. When such transfers occur, we ensure that appropriate safeguards are in place, including contractual protections equivalent to the standards described in this Policy. We do not transfer personal data to countries that do not provide adequate protection for personal information without implementing additional safeguards.

12. Children's Privacy

ave189 strictly prohibits access to its Services by anyone under the age of 21. We do not knowingly collect personal data from individuals under 21 years of age. If we discover that personal data has been collected from an underage individual, we will delete that data immediately and close the associated Account. If you believe a minor has registered an Account, please contact us immediately at [email protected].

13. Responsible Gaming and Privacy

In connection with our Responsible Gaming program, ave189 may process additional personal data to monitor gaming patterns, identify potential problem gambling indicators, and apply responsible gaming tools such as deposit limits and self-exclusion. This processing is carried out to protect Player welfare and constitutes a legitimate interest. Data collected for responsible gaming purposes is handled with the highest level of sensitivity and is never used for marketing purposes.

For more information about our responsible gaming tools and Player welfare resources, please visit our Responsible Gaming page.

14. Changes to This Privacy Policy

ave189 reserves the right to update or amend this Privacy Policy at any time. Material changes will be communicated to registered Players via email notification or a prominent notice on the Website prior to the changes taking effect. The "Last Updated" date at the top of this page reflects the most recent revision. Your continued use of our Services after any policy update constitutes acceptance of the revised terms.

We encourage you to review this Policy periodically to stay informed about how we protect your personal data. Archived versions of this Policy are available upon request.

15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact our Data Protection team:

By using ave189 Services, you confirm that you have read and understood this Privacy Policy and consent to the processing of your personal data as described above. Thank you for trusting ave189 with your information — we take that trust seriously.