Scope of This Policy: This Privacy Policy applies to all personal data collected and processed by atm189 ("we", "us", "our") in connection with the online betting platform accessible at https://atm189.cam. By registering an account or continuing to use the platform, you acknowledge that you have read and understood this Privacy Policy in full.
1. Introduction
atm189 is committed to protecting the privacy and security of every player who uses our platform. We recognize that the personal information you share with us carries real value, and we take our responsibility to handle it with care, transparency, and integrity seriously.
This Privacy Policy describes the categories of personal data we collect from players in Indonesia and internationally, the purposes for which that data is processed, the parties with whom it may be shared, how long it is retained, and the rights you may exercise in relation to your data. This Policy should be read together with our Terms & Conditions, which govern your use of the atm189 platform more broadly.
If you have questions about anything in this Privacy Policy or wish to exercise any of your data rights, please contact our Privacy Team directly at [email protected].
2. Definitions
In this Privacy Policy, the following terms carry the meanings set out below:
- "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, identification number, location data, online identifier, or any factor specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
- "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, dissemination, or erasure.
- "Data Controller" means atm189, the entity that determines the purposes and means of processing Personal Data.
- "Data Processor" means any third party that processes Personal Data on behalf of atm189, such as payment processors or KYC verification services.
- "Consent" means any freely given, specific, informed, and unambiguous indication of your wishes by which you agree to the processing of your Personal Data.
- "KYC" (Know Your Customer) means the identity verification process atm189 uses to confirm player identity and age before processing withdrawals.
- "Cookies" means small data files placed on your device by the atm189 website that help us recognize your browser and remember your preferences.
3. Data We Collect
atm189 collects several categories of Personal Data from players. The specific data collected depends on how you use our platform and which features you access. The main categories are set out below.
3.1 Registration & Account Data
When you create an account on atm189, we collect your full legal name, date of birth, residential address (street, city, postal code), email address, mobile phone number, and chosen username and password. We also collect your preferred language and currency settings (Indonesian Rupiah / IDR for all Indonesian players).
3.2 Identity Verification Data (KYC)
To comply with anti-money laundering regulations and to verify that you are at least 21 years of age, we collect copies of government-issued identification documents such as your Indonesian National ID (KTP), passport, or driving license, as well as proof of address documents (utility bills, bank statements) and selfie photographs for facial verification. This data is used solely for identity verification and is stored securely in accordance with data protection standards.
3.3 Payment & Financial Data
We collect information about the payment methods you use to deposit and withdraw funds, including bank account numbers, bank names (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata, Bank Danamon), e-wallet account numbers (OVO, DANA, GoPay, ShopeePay, LinkAja), and transaction history including deposit amounts, withdrawal amounts, and timestamps. All financial data is encrypted in transit and at rest.
3.4 Usage & Behavioral Data
We automatically collect information about your interactions with the atm189 platform, including betting history (sports bets on football matches like BRI Liga 1, EPL, La Liga; togel lottery draws; casino games; slot games), game preferences, login timestamps, session duration, IP addresses, device identifiers (device type, operating system, browser type), and clickstream data (pages visited, buttons clicked). This data helps us improve platform performance and detect fraudulent activity.
3.5 Communications Data
If you contact atm189 customer support via live chat, email, or phone, we retain records of those communications, including the content of your messages, attachments you send, and timestamps. We may also record phone calls for quality assurance and training purposes; you will be notified at the start of any recorded call.
3.6 Marketing Preferences
We collect information about your marketing communication preferences, including whether you have opted in to receive promotional emails, SMS messages, or push notifications about bonuses, seasonal promotions (Ramadhan, Idul Fitri, Indonesian Independence Day on 17 August), and new game launches. You may withdraw consent at any time.
4. How We Collect Data
atm189 collects Personal Data through the following channels:
- Directly from you: When you complete the registration form, submit KYC documents, make a deposit or withdrawal, place a bet, contact customer support, or update your account settings.
- Automatically via technology: Through cookies, web beacons, server logs, and similar tracking technologies that record your device information, IP address, browser type, and platform usage patterns.
- From third-party providers: From payment processors (to confirm transaction success), KYC verification services (to validate identity documents), and game providers (to deliver game results and RNG outputs).
- From publicly available sources: In limited cases, to verify information you provide or to investigate suspected fraudulent activity, we may reference publicly accessible databases or social media profiles.
5. How We Use Your Data
atm189 processes your Personal Data for the following specific purposes:
| Purpose | Description |
|---|---|
| Account Management | To create and maintain your atm189 account, authenticate your login, and enable you to update account settings. |
| Transaction Processing | To process deposits via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, and other approved methods; to process withdrawal requests; and to maintain accurate transaction records. |
| Identity Verification (KYC) | To verify that you are at least 21 years of age, a resident of Indonesia, and the legitimate owner of the payment methods you use, in compliance with anti-money laundering laws. |
| Fraud Prevention & Security | To detect and prevent fraudulent activity, bonus abuse, account takeovers, underage gambling, money laundering, and other prohibited conduct described in our Terms & Conditions. |
| Customer Support | To respond to your inquiries via live chat, email, or phone; to troubleshoot technical issues; and to resolve disputes. |
| Responsible Gaming | To enforce deposit limits, loss limits, session time caps, self-exclusion requests, and other player protection measures described on our Responsible Gaming page. |
| Marketing Communications | To send you promotional offers, bonus announcements, and newsletters where you have provided consent. You may unsubscribe at any time. |
| Platform Improvement | To analyze aggregated usage data, identify popular games and betting markets, optimize website performance, and develop new features. |
| Legal & Regulatory Compliance | To comply with international gaming license obligations, court orders, law enforcement requests, and other legal requirements. |
6. Legal Basis for Processing
Under applicable data protection laws, atm189 must have a valid legal basis for processing your Personal Data. We rely on the following legal grounds:
- Contractual Necessity: Processing is necessary to perform our contract with you (the Terms & Conditions), including account creation, transaction processing, and customer support.
- Legal Obligation: Processing is required to comply with laws and regulations, including KYC/AML obligations, tax reporting, and responses to lawful requests from authorities.
- Legitimate Interest: Processing is necessary for our legitimate business interests in preventing fraud, ensuring platform security, analyzing usage trends, and marketing to existing players, provided those interests are not overridden by your fundamental rights.
- Consent: Where required by law or where we process data for purposes beyond those strictly necessary for the contract, we obtain your explicit consent (e.g., for marketing communications). You may withdraw consent at any time without affecting the lawfulness of prior processing.
7. Data Sharing & Third-Party Disclosure
atm189 does not sell your Personal Data to third parties. We do, however, share data with the following categories of recipients where necessary to operate the platform and comply with legal obligations:
7.1 Payment Processors
We share payment-related data (account numbers, transaction amounts) with licensed Indonesian payment processors and e-wallet providers to facilitate deposits and withdrawals. These processors act as Data Processors under our instruction and are contractually bound to protect your data.
7.2 KYC & Verification Providers
We share identity documents and verification data with specialized third-party KYC verification services to confirm your identity, age, and address. These services use secure encryption and delete data immediately after verification is complete.
7.3 Game & Software Providers
We share limited data (username, bet amounts, game session identifiers) with licensed game studios such as Pragmatic Play, Evolution Gaming, Spribe, Pocket Games Soft, and Microgaming to deliver casino and slot game content. These providers do not receive your real name, financial details, or contact information.
7.4 Regulatory & Law Enforcement Authorities
We may disclose Personal Data to regulatory bodies, law enforcement agencies, courts, or other government authorities where required by law, court order, or regulatory request. We will notify you of such disclosure where legally permitted.
7.5 Professional Advisors
We may share data with external legal counsel, auditors, accountants, and other professional advisors who are bound by confidentiality obligations and process data solely for the purpose of advising atm189.
Cross-Border Data Transfers: Some of our service providers and game studios are located outside Indonesia. When we transfer Personal Data internationally, we ensure that appropriate safeguards are in place, such as standard contractual clauses, adequacy decisions, or binding corporate rules, to protect your data to a standard equivalent to that required under Indonesian data protection principles.
8. Data Retention
atm189 retains Personal Data only for as long as necessary to fulfill the purposes for which it was collected, to comply with legal and regulatory obligations, and to resolve disputes or enforce our agreements. Specific retention periods vary by data category:
- Account & Transaction Data: Retained for the duration of your account lifecycle plus 7 years after account closure to comply with financial record-keeping and anti-money laundering regulations.
- KYC Documents: Retained for 7 years after account closure or the last transaction, whichever is later, as required by international AML standards.
- Usage & Behavioral Data: Aggregated and anonymized usage data may be retained indefinitely for statistical analysis. Identifiable usage data is retained for 3 years from the date of collection.
- Communications Records: Live chat transcripts and support emails are retained for 3 years from the date of the last communication. Phone call recordings are retained for 1 year unless needed for dispute resolution.
- Marketing Preferences: Retained until you unsubscribe or request deletion, after which we retain only a suppression record to ensure we do not contact you again.
When Personal Data is no longer required, it is securely deleted or anonymized so that it can no longer be associated with you personally.
9. Data Security Measures
atm189 employs industry-standard technical and organizational measures to protect your Personal Data against unauthorized access, loss, destruction, alteration, or disclosure. Our security framework includes:
- 256-bit SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using bank-grade SSL/TLS protocols.
- Data-at-Rest Encryption: Personal Data stored on our servers, including KYC documents and financial records, is encrypted using AES-256 encryption.
- Access Controls: Strict role-based access controls ensure that only authorized personnel can access Personal Data, and only to the extent necessary for their job function.
- Multi-Factor Authentication: Administrative access to data systems requires multi-factor authentication. We encourage players to enable two-factor authentication on their accounts.
- Regular Security Audits: We conduct regular vulnerability assessments, penetration testing, and third-party security audits to identify and remediate potential weaknesses.
- Incident Response Plan: In the event of a data breach, we have a documented incident response plan that includes immediate containment, forensic investigation, notification to affected players, and reporting to relevant authorities where required by law.
Your Responsibility: While atm189 implements robust security measures, you are also responsible for protecting your account. Use a strong, unique password; do not share your login credentials with anyone; log out after each session on shared devices; and contact us immediately if you suspect unauthorized access.
11. Your Data Protection Rights
Under applicable data protection laws, you have the following rights in relation to your Personal Data held by atm189:
11.1 Right of Access
You have the right to request a copy of the Personal Data we hold about you. We will provide this in a structured, commonly used, machine-readable format within 30 days of your request, free of charge for the first request each year.
11.2 Right to Rectification
If any Personal Data we hold about you is inaccurate or incomplete, you have the right to request that we correct or complete it. You can update most account information directly through your account settings dashboard.
11.3 Right to Erasure (Right to be Forgotten)
You have the right to request deletion of your Personal Data where: (a) it is no longer necessary for the purposes for which it was collected; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to processing and there are no overriding legitimate grounds; or (d) the data has been unlawfully processed. This right is subject to our legal obligation to retain certain records (e.g., transaction history for 7 years).
11.4 Right to Restriction of Processing
You have the right to request that we limit the processing of your Personal Data in certain circumstances, such as when you contest the accuracy of the data or object to processing based on legitimate interests. During restriction, we may store the data but not use it for other purposes.
11.5 Right to Data Portability
You have the right to receive your Personal Data in a structured, commonly used, machine-readable format and to transmit that data to another service provider where technically feasible.
11.6 Right to Object
You have the right to object to processing of your Personal Data where we rely on legitimate interests as the legal basis. You also have an absolute right to object to processing for direct marketing purposes at any time.
11.7 Right to Withdraw Consent
Where processing is based on your consent, 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.
How to Exercise Your Rights: To exercise any of the rights above, please contact our Privacy Team at [email protected] with "Data Rights Request" in the subject line. We will respond within 30 days. If we decline your request, we will explain why and inform you of your right to lodge a complaint with a data protection authority.
12. Protection of Minors
atm189 does not knowingly collect or process Personal Data from any individual under the age of 21. The platform is strictly for adults only (21+). If we become aware that we have inadvertently collected data from a minor, we will delete that data immediately and permanently close the associated account. All balances in accounts determined to belong to minors will be forfeited.
Parents and guardians are encouraged to monitor their children's internet usage and to use parental control tools to prevent minors from accessing online gambling platforms. If you believe a minor has created an account on atm189, please contact us immediately at [email protected].
13. Changes to This Privacy Policy
atm189 reserves the right to amend this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or business operations. When we make material changes, we will provide notice via a prominent announcement on the platform and, where practicable, by email to the address registered on your account.
The date of the most recent revision is displayed at the top of this page. Your continued use of the atm189 platform after a revised Privacy Policy takes effect constitutes your acceptance of the revised terms. If you do not agree to any change, you must immediately cease using the platform and contact support to request account closure.
14. Contact & Complaints
If you have questions, concerns, or complaints about this Privacy Policy or about how atm189 processes your Personal Data, please contact our Privacy Team:
- Email: [email protected]
- Subject Line: "Privacy Policy Inquiry" or "Data Rights Request"
- Response Time: Within 30 days of receipt
- Escalation: If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority or supervisory body.
For general customer support inquiries unrelated to privacy, please use our 24/7 live chat service or visit our FAQ page for immediate answers to common questions.