Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") is issued by sule96 ("sule96," "we," "us," or "our") and applies to all personal data collected through the website at https://sule96.cam, our mobile-optimized platform, and all associated services offered to players based primarily in Indonesia. By accessing or using the sule96 platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein.

This Policy is designed to comply with internationally recognized data protection principles. Where Indonesian data protection provisions apply, we observe those requirements with the same diligence. If you have questions or wish to exercise your privacy rights, please contact us at [email protected].

2. Definitions

• "Personal Data" — any information that identifies or can reasonably identify you as an individual, including name, email address, date of birth, financial account details, and IP address.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, transfer, or deletion.
• "Data Controller" — sule96, which determines the purposes and means of processing your Personal Data.
• "Third Party" — any natural or legal person other than you, sule96, or sule96's authorized processors who operates independently of sule96.
• "Cookies" — small text files placed on your device by a web server to store information about your visit and preferences.
• "KYC" — Know Your Customer, the identity-verification procedures required under anti-money laundering regulations.

3. Data We Collect

3.1 Information You Provide Directly

When you register an account, verify your identity, make deposits or withdrawals, or contact our support team, we collect the following categories of data:

• Identity Data: full legal name, date of birth, Indonesian National Identity Card (KTP) number, and a photograph of your identity document.
• Contact Data: email address, Indonesian mobile phone number, and residential address.
• Financial Data: bank account details (for BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon accounts), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja), and transaction history.
• Verification Data: selfie photographs, proof of address documents, and any additional KYC materials requested by our compliance team.

3.2 Data Collected Automatically

When you access our platform, our servers automatically record certain technical information:

• Device & Technical Data: IP address, browser type and version, operating system, device type, screen resolution, and time-zone setting (typically Western Indonesia Time, WIB/UTC+7).
• Usage Data: pages visited, games played, session duration, click paths, bet history, and deposit or withdrawal activity.
• Cookie & Tracking Data: session identifiers, persistent preference cookies, and analytics identifiers (see Section 8 for full cookie details).

3.3 Data from Third Parties

We may receive data about you from third-party KYC verification services, fraud-detection providers, and payment processors when you initiate transactions. This data is used solely to verify your identity, process payments, and prevent fraud.

4. How We Use Your Data

sule96 processes your Personal Data for the following purposes:

1. Account Management: creating, maintaining, and securing your player account throughout your relationship with sule96.
2. Identity Verification: conducting KYC checks to confirm your age (21+), residency in Indonesia, and identity in compliance with anti-money laundering obligations.
3. Transaction Processing: facilitating deposits via local Indonesian banks (BCA, BRI, BNI, Mandiri) and e-wallets, as well as processing withdrawal requests to your verified bank account.
4. Customer Support: responding to inquiries, resolving disputes, and communicating important account or platform updates via email, live chat, or WhatsApp.
5. Responsible Gaming: monitoring gaming behavior to identify patterns that may indicate problem gambling, and to enforce self-exclusion, deposit limits, and other protective tools you have activated.
6. Platform Improvement: analyzing aggregated usage data to improve game selection, website performance, and the overall player experience.
7. Fraud Prevention and Security: detecting and preventing unauthorized access, fraudulent transactions, money laundering, and other unlawful activities.
8. Legal Compliance: retaining records as required by applicable law and responding to lawful requests from regulatory or law-enforcement authorities.
9. Marketing (with consent only): sending promotional emails, bonus notifications, or personalized offers where you have explicitly opted in. You may withdraw marketing consent at any time.

5. Legal Bases for Processing

Every processing activity at sule96 rests on one or more of the following legal bases:

• Contract Performance: processing necessary to provide the gaming services you have requested, including account registration, payment processing, and customer support.
• Legal Obligation: processing required to comply with anti-money laundering laws, age-verification requirements, and other applicable legal obligations.
• Legitimate Interests: processing for fraud prevention, platform security, and internal analytics, where those interests do not override your fundamental privacy rights.
• Consent: processing for optional marketing communications, where you have freely given specific and informed consent. Withdrawal of consent does not affect the lawfulness of processing prior to withdrawal.

6. Data Sharing and Disclosure

6.1 Authorized Service Providers

We share Personal Data with carefully vetted third-party service providers who assist us in operating the sule96 platform. These include payment processors, KYC and identity-verification partners, cloud infrastructure providers, fraud-detection systems, and customer-support software vendors. All such providers are contractually bound to process your data only on our documented instructions and to maintain equivalent security standards.

6.2 Regulatory and Legal Disclosure

We may disclose your Personal Data to competent authorities, law-enforcement agencies, or regulatory bodies when required to do so by applicable law, court order, or lawful governmental request. We will notify you of any such disclosure to the extent permitted by law.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or a portion of our business assets, your Personal Data may be transferred to the acquiring entity, subject to equivalent privacy protections. You will be notified of any such transfer and your rights in relation to it.

6.4 No Sale of Personal Data

sule96 does not sell, rent, or trade your Personal Data to any third party for their own marketing or commercial purposes. Period.

7. Data Retention

We retain your Personal Data only for as long as necessary to fulfil the purposes described in this Policy, including satisfying legal, accounting, and reporting requirements. Specific retention periods are as follows:

• Account and Identity Data: retained for the duration of your account plus a minimum of five years following account closure, in accordance with anti-money laundering record-keeping obligations.
• Transaction Records: retained for a minimum of five years from the date of each transaction.
• Customer Support Correspondence: retained for three years from the date of the most recent interaction.
• Marketing Consent Records: retained until consent is withdrawn and for one year thereafter as evidence of your prior consent.
• Technical Logs: typically retained for 90 days for security analysis and platform optimization.

Upon expiry of the applicable retention period, data is securely deleted or anonymized so that it can no longer be associated with you.

8. Cookies and Tracking Technologies

sule96 uses cookies and similar tracking technologies to operate and improve the platform. The categories of cookies we deploy are:

• Strictly Necessary Cookies: essential for basic platform functionality, including session management and security. These cannot be disabled without impairing platform operation.
• Performance and Analytics Cookies: collect anonymous, aggregated information about how visitors use our platform, enabling us to identify popular features and areas for improvement.
• Functionality Cookies: remember your preferences — such as language setting and login state — to provide a more personalized experience.
• Marketing and Targeting Cookies: used only with your explicit consent to deliver relevant promotional content. You may decline or withdraw consent at any time through your browser settings.

You can control cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the sule96 platform.

9. Data Security

We implement a comprehensive suite of technical and organizational measures to protect your Personal Data against unauthorized access, loss, alteration, or disclosure:

• Transport Layer Security (TLS): all data transmitted between your browser and our servers is encrypted using current TLS standards.
• At-Rest Encryption: sensitive data stored in our databases is encrypted using AES-256 or equivalent standards.
• Access Controls: Personal Data is accessible only to sule96 personnel and authorized processors who require it to perform their duties, governed by the principle of least privilege.
• Two-Factor Authentication: internal systems handling Personal Data require multi-factor authentication for all administrative access.
• Regular Security Audits: we conduct periodic vulnerability assessments and penetration tests to identify and remediate security weaknesses before they can be exploited.
• Incident Response: we maintain a documented data-breach response procedure. In the event of a breach affecting your rights and freedoms, we will notify you and relevant authorities within the timeframes required by applicable law.

While we employ industry-standard security practices, no method of electronic transmission or storage is 100% secure. You are responsible for keeping your account credentials confidential and for notifying us immediately if you suspect unauthorized access to your account.

10. Your Privacy Rights

Subject to applicable law, you have the following rights in relation to your Personal Data held by sule96:

• Right of Access: you may request a copy of the Personal Data we hold about you, along with information about how it is being processed.
• Right to Rectification: if any data we hold about you is inaccurate or incomplete, you have the right to have it corrected without undue delay.
• Right to Erasure: in certain circumstances, you may request that we delete your Personal Data. Note that we may be required to retain certain data to comply with legal obligations, and erasure requests do not override those requirements.
• Right to Restriction: you may ask us to suspend processing of your Personal Data in certain circumstances, for example while the accuracy of data is being contested.
• Right to Data Portability: where processing is based on your consent or a contract, you may request that we provide your Personal Data in a structured, commonly used, machine-readable format.
• Right to Object: you may object to processing based on legitimate interests at any time. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: where processing relies on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of the above rights, please contact our Data Protection team at [email protected] with your full name, registered email address, and a clear description of your request. We will respond within 30 days. We may request proof of identity before processing your request to prevent unauthorized disclosure.

11. International Data Transfers

sule96 primarily stores and processes data on servers located in secure data centers. In some cases, data may be transferred to or accessed by authorized service providers operating in other jurisdictions. Wherever such transfers occur, we ensure that appropriate safeguards are in place — including contractual protections equivalent to internationally recognized data transfer mechanisms — so that your Personal Data continues to receive a level of protection consistent with this Policy.

12. Third-Party Links and Services

The sule96 platform may reference or integrate with third-party game providers such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Pocket Games Soft for the purpose of delivering game content. These providers operate their own privacy practices. While we select partners who meet high data protection standards, sule96 is not responsible for the privacy practices of third-party software providers. We encourage you to review the privacy policies of any third-party services you interact with.

13. Children's Privacy

The sule96 platform is intended exclusively for adults aged 21 and over who are residents of Indonesia. We do not knowingly collect, use, or disclose Personal Data relating to individuals under the age of 21. If we become aware that a minor has provided us with Personal Data, we will take immediate steps to close the associated account, delete all related data, and void any transactions. If you believe a minor has registered on our platform, please notify us immediately at [email protected].

14. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes, we will post the revised Policy on this page with an updated "Last Updated" date and, where appropriate, notify you by email. Your continued use of the sule96 platform after the effective date of any revision constitutes your acceptance of the updated Policy. We encourage you to review this page periodically.

15. Governing Law

This Privacy Policy is governed by and construed in accordance with applicable international data protection principles and the laws of the jurisdiction in which sule96 operates. Any disputes arising from or in connection with this Policy shall be subject to the exclusive jurisdiction of the competent courts in the relevant jurisdiction. Nothing in this clause limits your statutory rights under applicable Indonesian consumer protection or data protection legislation.

16. Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or our data practices, or if you wish to exercise any of your privacy rights, please contact our Data Protection team through the following channel:

• Email: [email protected]
• Response Time: We aim to acknowledge all privacy-related inquiries within 48 hours and provide a substantive response within 30 calendar days.
• Support Hours: Our customer support team is available 24 hours a day, 7 days a week, in Western Indonesia Time (WIB, UTC+7).

Please include your full registered name, account email address, and a clear description of your request or concern so that we can assist you as efficiently as possible.