Privacy Policy

1. Introduction

This Privacy Policy describes how gas189 (referred to herein as "gas189," "we," "us," or "our"), the operator of the online gaming platform available at https://gas189.cam, collects, uses, processes, stores, and discloses personal information relating to users of our services ("you" or "your").

gas189 is committed to handling personal data responsibly and in accordance with applicable international data protection standards. This policy applies to all personal data processed in connection with your use of the gas189 website, mobile experience, customer support channels, and any other service we provide. It should be read alongside our Terms & Conditions and our Responsible Gaming policy, both of which form part of the overall agreement governing your use of the platform.

We primarily serve players based in Indonesia, including residents of Jakarta, Surabaya, Medan, Bandung, Bali, Yogyakarta, Semarang, and Makassar. Indonesian residents are subject to local laws and regulations in addition to the international standards described in this policy.

2. Definitions

• "Personal Data" means any information relating to an identified or identifiable natural person — including name, identification number, location data, online identifier, or any factor specific to that person's physical, economic, or social identity.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, alteration, retrieval, disclosure, transmission, or deletion.
• "Data Controller" means the entity that determines the purposes and means of Processing Personal Data. gas189 is the Data Controller for all data collected via the platform.
• "Data Processor" means a natural or legal person that processes Personal Data on behalf of the Data Controller (e.g., our payment gateway partners, cloud hosting provider).
• "Consent" means a freely given, specific, informed, and unambiguous indication of agreement by the data subject to the processing of their Personal Data.
• "KYC" (Know Your Customer) refers to the identity and age verification process required under our licensing obligations.
• "Cookie" means a small data file placed on your device by a website to record information about your browsing activity.

3. Data We Collect

gas189 collects the following categories of personal data during the course of your use of the platform:

3.1 Identity & Contact Data

• Full legal name (as it appears on your government-issued ID)
• Date of birth
• Nationality and country of residence
• Residential address (street, city, province, postal code)
• Email address
• Mobile phone number
• Government-issued identification number (KTP number for Indonesian residents; passport number for foreign nationals)

3.2 Financial Data

• Bank account details (bank name, account number, account holder name) for Indonesian banks including BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, and BSI
• E-wallet identifiers for OVO, DANA, GoPay, ShopeePay, and LinkAja
• Transaction history (deposits, withdrawals, wagers, winnings, bonus credits)
• Source of funds declarations where required under anti-money-laundering procedures

3.3 Technical & Usage Data

• IP address and approximate geolocation (country, province, city)
• Device type, operating system, and browser information
• Session duration, pages visited, and features accessed
• Clickstream data and in-platform navigation patterns
• Login timestamps and access logs

3.4 Communications Data

• Content of messages sent to our customer support team via live chat or email
• Records of complaints or disputes raised against your account
• Marketing preference settings and communication opt-in/opt-out records

3.5 KYC Verification Documents

• Scanned copies or photographs of government-issued identity documents
• Utility bills or bank statements submitted as proof of address
• Any supplementary documents requested for enhanced due diligence

4. How Data Is Collected

We collect your personal data through the following means:

Collection Method	Data Categories Collected
Account Registration	Identity data, contact data, date of birth, password (hashed)
KYC Submission	Identity documents, proof of address, financial ownership docs
Deposit / Withdrawal Transactions	Bank account or e-wallet details, transaction amounts, timestamps
Platform Activity	Betting history, game sessions, bonus usage, wagering records
Cookies & Analytics	IP address, device data, session data, clickstream
Customer Support Interactions	Communications content, issue records, resolution notes
Third-Party Verification Services	Identity verification results, fraud screening signals

5. Purpose & Legal Basis for Processing

gas189 processes your personal data for specific, legitimate purposes. Each processing activity is grounded in one of the following legal bases: (a) performance of a contract with you; (b) compliance with a legal obligation; (c) your explicit consent; or (d) our legitimate interests, provided these do not override your rights.

5.1 Contract Performance

We process your identity, contact, and financial data to create and manage your Account, process deposits and withdrawals, settle bets and casino game outcomes, and deliver customer support. Without this processing, we cannot provide the services you have contracted for.

5.2 Legal & Regulatory Compliance

We are required under our international gaming licence to verify the identity and age of all registered users (KYC), conduct anti-money-laundering checks, retain transaction records for audit purposes, and report suspicious activity to relevant authorities. This processing is mandatory and cannot be waived by user consent.

5.3 Legitimate Interests

We process technical and usage data to maintain platform security, detect and prevent fraud, improve user experience, and conduct platform analytics. These activities serve our legitimate business interests and do not materially impact your privacy rights, given the technical and aggregated nature of the data involved.

5.4 Consent-Based Processing

Where we send you promotional communications (bonus offers, new game announcements, seasonal promotions tied to events such as Idul Fitri, Ramadhan, or Indonesian Independence Day), we do so only with your explicit opt-in consent. You may withdraw this consent at any time by updating your communication preferences in your Account settings or by contacting our support team.

6. Data Sharing & Disclosure

gas189 does not sell, rent, or trade your personal data to any third party for commercial purposes. We share data only in the following limited and controlled circumstances:

6.1 Payment Processors & Banking Partners

We share the minimum financial data necessary with Indonesian banking partners (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, BSI) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to process your deposit and withdrawal transactions. These parties act as independent Data Controllers for their own processing activities and are governed by their own privacy policies.

6.2 Identity Verification & Fraud Prevention Services

We engage third-party KYC and identity verification providers to assist in confirming the authenticity of identity documents and conducting fraud screening. These providers act as Data Processors under binding data processing agreements and may not use your data for any purpose other than providing verification services to gas189.

6.3 IT Infrastructure & Cloud Services

Your data is stored on secure cloud infrastructure operated by our technology partners. All such providers are subject to data processing agreements requiring them to implement equivalent security standards and to process data only on our documented instructions.

6.4 Legal & Regulatory Authorities

We may disclose personal data to our licensing authority, law enforcement agencies, or financial intelligence units where we are legally obligated to do so, or where we reasonably believe disclosure is necessary to prevent fraud, money laundering, or other criminal activity. Such disclosures are made under strict confidentiality and only to the extent required by law.

6.5 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of gas189's assets, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify affected users before any such transfer occurs and ensure the receiving entity is bound by privacy obligations no less protective than those in this policy.

7. International Data Transfers

gas189 operates internationally, and your personal data may be transferred to and processed in countries outside of Indonesia. Where such transfers occur, we ensure that appropriate safeguards are in place, such as standard contractual clauses, binding corporate rules, or other mechanisms recognised under applicable data protection law, to maintain the same level of protection that this policy affords your data within Indonesia.

8. Data Retention

gas189 retains your personal data for as long as necessary to fulfil the purposes described in this policy and to comply with applicable legal and regulatory obligations. Specific retention periods are as follows:

• Account and identity data: Retained for the lifetime of your Account and for a minimum of 5 years following Account closure, in compliance with anti-money-laundering record-keeping requirements.
• Financial transaction records: Retained for a minimum of 5 years following each transaction, as required by our licensing authority.
• KYC documents: Retained for a minimum of 5 years following Account closure or the completion of the last transaction, whichever is later.
• Customer support records: Retained for 3 years following the resolution of the support interaction.
• Technical and usage logs: Retained for up to 12 months from the date of generation, unless longer retention is required for security investigations.
• Marketing consent records: Retained for the duration of consent and for up to 2 years following withdrawal of consent, as evidence of compliance.

When personal data is no longer required, we securely delete or anonymise it in accordance with our internal data destruction procedures.

9. Cookies & Tracking Technologies

9.1 What We Use

gas189 uses cookies and similar tracking technologies (local storage, session storage, pixel tags) to enable core platform functionality, remember your preferences, maintain your logged-in session, analyse usage patterns, and deliver relevant promotional content.

9.2 Cookie Categories

• Strictly Necessary Cookies: Essential for the platform to function. These cannot be disabled without breaking core features such as login session management and deposit flow. No consent is required for these cookies.
• Performance & Analytics Cookies: Collect aggregated, anonymised data about how users navigate the platform, which pages are most visited, and where errors occur. Used to improve platform performance.
• Functional Cookies: Remember your preferences (such as your preferred language, notification settings, or last-used payment method) to personalise your experience.
• Marketing Cookies: Used to track the effectiveness of promotional campaigns and, where consent is given, to serve relevant offers. You may opt out of marketing cookies via your Account preferences.

9.3 Managing Cookies

You can control non-essential cookies through your browser settings or your gas189 Account privacy preferences. Please note that disabling certain cookies may affect the functionality of the platform. Your browser documentation will explain how to manage cookie settings for your specific browser.

10. Your Privacy Rights

Subject to applicable law and our legitimate interests as a licensed gaming operator, you have the following rights with respect to your personal data held by gas189:

R ight	Description	How to Exercise
Right of Access	Request a copy of the personal data we hold about you, along with information about how it is used.	Contact [email protected] with subject "Data Access Request"
Right to Rectification	Request correction of inaccurate or incomplete personal data. Some corrections may require re-submission of KYC documents.	Update via Account settings or contact support
Right to Erasure	Request deletion of your personal data where we no longer have a lawful basis to retain it. Note: regulatory retention obligations may override this right in certain cases.	Submit a written erasure request to [email protected]
Right to Restriction	Request that we limit processing of your data while a dispute or rectification request is being resolved.	Contact support with subject "Data Restriction Request"
Right to Data Portability	Receive a structured, machine-readable copy of personal data you have provided to us, where processing is based on consent or contract.	Submit a portability request to [email protected]
Right to Object	Object to processing based on legitimate interests, including direct marketing. Marketing opt-outs take effect within 48 hours.	Use the unsubscribe link in any marketing email or contact support
Right to Withdraw Consent	Withdraw consent for any processing activity based solely on your consent, without affecting the lawfulness of prior processing.	Update preferences in Account settings or contact support

We will respond to all verified privacy rights requests within 30 days of receipt. In complex cases, we may extend this period by a further 60 days, in which case we will notify you of the extension and the reason for it. We may need to verify your identity before fulfilling any request to protect against fraudulent or unauthorised access to another person's data.

11. Children's Privacy

The gas189 platform is strictly intended for adults aged 21 and over. We do not knowingly collect, process, or store personal data from any person under the age of 21. If we become aware that personal data has been submitted by or on behalf of an individual under 21, we will immediately suspend the associated Account, delete or securely destroy all related personal data, and — where applicable — report the incident to our licensing authority.

Parents and guardians who believe their child may have accessed or registered on gas189 should contact us immediately at [email protected] so that we can investigate and take appropriate action without delay.

12. Security Measures

gas189 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. Our security framework includes:

• SSL/TLS Encryption: All data transmitted between your device and the gas189 platform is encrypted using industry-standard TLS 1.2 or higher, ensuring that intercepted traffic cannot be read by third parties.
• Data Encryption at Rest: Sensitive personal and financial data stored in our databases is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data within gas189's systems is restricted on a strict need-to-know basis. All staff with access to personal data undergo regular data protection training and are bound by confidentiality obligations.
• Two-Factor Authentication (2FA): Users are encouraged to enable 2FA on their Accounts to provide an additional layer of protection against unauthorised login.
• Penetration Testing & Vulnerability Scanning: Our platform undergoes regular third-party security audits and automated vulnerability scanning to identify and remediate potential weaknesses before they can be exploited.
• Incident Response: We maintain a documented data breach response procedure. In the event of a breach that is likely to result in a risk to your rights and freedoms, we will notify affected users and the relevant supervisory authority within the timeframe required by applicable law.

13. Third-Party Links & Services

The gas189 platform may contain references to third-party game studios (such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft) whose software is integrated into our platform. While we vet all technology partners for security and compliance, gas189 is not responsible for the privacy practices of these third-party technology providers beyond the scope of our data processing agreements with them.

Additionally, any links to external websites or resources that may appear in informational content on our platform are provided for reference only. gas189 has no control over the content or privacy practices of external sites and encourages you to review the privacy policy of any third-party site you visit.

14. Amendments to This Policy

gas189 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or our platform's features. When material changes are made, we will notify registered users via email and/or a prominent notice on the platform at least 7 days before the revised policy takes effect.

The date of the most recent revision is always displayed at the top of this page. Your continued use of the platform following the effective date of any amendment constitutes acceptance of the revised Privacy Policy. If you do not agree with any amendment, you should cease using the platform and request Account closure in accordance with our Terms & Conditions.

15. Contact & Data Protection Officer

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way in which gas189 handles your personal data, please contact our dedicated privacy team using the details below:

• Privacy & Data Protection Enquiries: [email protected] — please use the subject line "Privacy Enquiry" for fastest routing.
• Response Time: We aim to acknowledge all privacy-related correspondence within 2 business days and to provide a substantive response within 30 days.
• Support Hours: Our customer support team is available 24 hours a day, 7 days a week (WIB, UTC+7).

If you are not satisfied with our response to a privacy complaint, you have the right to escalate your complaint to the supervisory authority in the jurisdiction where gas189 is licensed, or to seek independent legal advice in your local jurisdiction.