Section 01
Definitions
In this Policy, the following terms carry the meanings set out below unless the context requires otherwise:
- "Personal Data" means any information relating to an identified or identifiable natural person, including name, identification number, location data, online identifiers, and factors specific to the physical, economic, cultural, or social identity of that person.
- "Processing" means any operation or set of operations performed on Personal Data, including collection, recording, storage, alteration, retrieval, use, disclosure, transmission, restriction, erasure, or destruction.
- "Data Controller" means the entity that determines the purposes and means of Processing Personal Data — in this context, tgl279.
- "Data Processor" means a third party that processes Personal Data on behalf of tgl279 under a contractual arrangement and subject to tgl279's instructions.
- "Member" means any natural person who has registered an Account on the Platform.
- "KYC" means Know Your Customer — the identity verification process required before certain account functions (notably withdrawal of funds above defined thresholds) become available.
- "AML" means Anti-Money Laundering — the set of legal obligations and internal procedures designed to prevent the Platform from being used to conceal the proceeds of criminal activity.
Section 02
Data Controller
tgl279 acts as the Data Controller in respect of all Personal Data collected through the Platform. As Data Controller, tgl279 is responsible for ensuring that Personal Data is processed lawfully, fairly, and transparently, and that appropriate technical and organisational measures are in place to protect it against unauthorised access, loss, alteration, or destruction.
Where tgl279 engages third-party service providers to process Personal Data on its behalf — such as payment processors, game studios, or cloud infrastructure providers — those parties act as Data Processors under written agreements that bind them to tgl279's data protection standards and prohibit them from using Member data for their own independent purposes.
Section 03
Data We Collect
tgl279 collects Personal Data through the following channels:
- Data you provide directly: During account registration, KYC submission, deposit and withdrawal requests, support interactions, and any other voluntary submission of information to the Platform.
- Data collected automatically: When you access the Platform, our servers automatically record technical data including your IP address, device fingerprint, browser type and version, operating system, page visit timestamps (expressed in WIB, UTC+7), session duration, and referring URL.
- Data from payment partners: When you make a deposit or withdrawal via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, or LinkAja, tgl279 receives a transaction confirmation record including the masked payment identifier, transaction amount in IDR, and timestamp. Full bank account numbers or e-wallet credentials are never transmitted to or stored by tgl279's core systems.
- Data from KYC and fraud-prevention services: tgl279 may use third-party identity verification and sanctions-screening services to validate the documents you submit during KYC. These services return a verification decision to tgl279; they do not retain your documents beyond the period necessary to produce that decision.
Section 04
Legal Basis for Processing
tgl279 processes your Personal Data on the following legal bases:
- Contractual necessity: Processing your identity data, contact data, and financial data is necessary to perform the contract between tgl279 and you (i.e., to provide the Platform services you have signed up for, including account management, bet placement, and payment processing).
- Legal obligation: tgl279 is required by its international gaming licence conditions and applicable AML regulations to collect and retain certain categories of Personal Data, including KYC documents and transaction records. This processing is mandatory and cannot be opted out of while you remain a Member.
- Legitimate interests: tgl279 processes technical and behavioural data on the basis of its legitimate interest in maintaining platform security, preventing fraud, detecting multi-accounting, and improving the Member experience — provided this interest is not overridden by your fundamental privacy rights.
- Consent: Where tgl279 sends you optional marketing communications (e.g., promotional email notifications about bonuses or seasonal offers during Idul Fitri, Ramadhan, or other holidays), this processing is based on your consent, which you may withdraw at any time by contacting our support team.
Section 05
How We Use Your Data
tgl279 uses your Personal Data exclusively for the following defined purposes:
- Account management: Creating and maintaining your Member account, verifying your identity and age (21+ requirement), and managing your account settings and preferences.
- Service delivery: Processing your bets, settling wagers, crediting winnings, and managing deposits and withdrawals in Indonesian Rupiah (IDR) via your chosen payment method.
- KYC and compliance: Verifying your identity documents, screening against sanctions lists, and maintaining the records required by our licensing authority and AML obligations.
- Fraud prevention and security: Detecting and preventing unauthorised account access, multi-accounting, payment fraud, money laundering, and any other activity that threatens the integrity of the Platform or its Members.
- Responsible gaming: Monitoring betting patterns for indicators of problem gambling behaviour and, where appropriate, applying responsible gaming interventions such as deposit limits or account restrictions in accordance with our Responsible Gaming policy.
- Customer support: Responding to your enquiries, resolving disputes, and maintaining records of support interactions for quality assurance purposes.
- Platform improvement: Analysing aggregated, anonymised usage data to understand how Members interact with the Platform and to identify areas for improvement.
- Marketing communications: Sending you promotional notifications about bonuses, new games, and seasonal promotions — only where you have provided consent and only via the contact channels you have registered.
tgl279 does not use your Personal Data for automated decision-making that produces legal or similarly significant effects on you, other than the automated fraud-detection systems that may flag your account for human review.
Section 06
Data Sharing & Third Parties
tgl279 does not sell your Personal Data. We share Personal Data with third parties only in the following limited and controlled circumstances:
- Payment processors: BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata, OVO, DANA, GoPay, ShopeePay, and LinkAja receive only the information strictly necessary to execute your payment instructions — typically a transaction amount in IDR and a masked account reference. These partners operate under their own privacy frameworks and are responsible for data protection within their own systems.
- Game content providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Pocket Games Soft, and Spribe receive a pseudonymous player session token to deliver game content. They do not receive your name, identity documents, or financial data.
- Identity verification services: Third-party KYC providers receive your identity documents solely for the purpose of producing a verification decision. Document copies are not retained by these providers beyond the verification window.
- Regulatory and law enforcement authorities: tgl279 will disclose Personal Data to competent regulatory authorities, law enforcement agencies, or courts where required to do so by applicable law, by our licensing conditions, or by a valid legal order. We will notify you of such disclosure where we are legally permitted to do so.
- Business transfers: In the event of a merger, acquisition, or sale of all or a substantial part of tgl279's business assets, Personal Data held by tgl279 may be transferred to the acquiring entity, subject to that entity's commitment to honour the protections described in this Policy.
✅ Our No-Sale Guarantee
Under no circumstances does tgl279 sell, rent, auction, or otherwise monetise your Personal Data to advertising networks, data brokers, or any third party whose primary purpose is commercial exploitation of personal information.
Section 07
Cookies & Tracking Technologies
tgl279 uses the following categories of cookies and similar client-side technologies when you visit the Platform:
- Strictly necessary cookies: These cookies are essential for the Platform to function. They maintain your authenticated session, store your language and display preferences, and protect against cross-site request forgery (CSRF). These cookies cannot be disabled without impairing Platform functionality.
- Analytics cookies: tgl279 uses first-party analytics cookies to measure page load performance, feature usage rates, and navigation paths through the Platform. This data is aggregated and anonymised before analysis; it is not used to build individual Member profiles.
- Fraud-prevention cookies: Device fingerprinting cookies help tgl279 identify suspicious login attempts, detect multi-accounting, and protect your account from unauthorised access.
- Personalisation cookies: These cookies remember your in-game preferences, preferred payment method, and recently visited game categories to provide a more efficient experience on return visits.
tgl279 does not deploy third-party advertising cookies, social-media tracking pixels, or behavioural retargeting scripts. You may clear or block cookies at any time using your browser settings. Note that disabling strictly necessary cookies will prevent you from logging into your Account.
Section 08
Data Security
tgl279 implements a layered security architecture to protect your Personal Data against unauthorised access, accidental loss, alteration, or disclosure. Our security measures include, but are not limited to:
- Transport security: All data in transit between your device and tgl279 servers is encrypted using TLS 1.2 or higher (256-bit AES encryption).
- Storage security: Personal Data at rest is stored on encrypted drives within access-controlled data centre environments. Payment credentials are never stored in plain text.
- Access controls: Access to systems containing Personal Data is restricted to authorised tgl279 personnel on a strict need-to-know basis, enforced through role-based access control (RBAC) and multi-factor authentication (MFA).
- Monitoring and incident response: tgl279 operates continuous security monitoring of its infrastructure. In the event of a data breach that is reasonably likely to result in a risk to your rights and freedoms, tgl279 will notify affected Members without undue delay and will take immediate remediation action.
- Penetration testing: tgl279 commissions periodic third-party penetration tests of its Platform infrastructure to identify and address potential vulnerabilities before they can be exploited.
While tgl279 takes all reasonable steps to protect your data, no system is entirely immune to security risk. You are responsible for maintaining the security of your own account credentials and for notifying tgl279 immediately if you suspect any unauthorised access to your Account.
Section 09
Data Retention
tgl279 retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by our legal or regulatory obligations. Our standard retention schedule is as follows:
- Active account data: Retained for the full duration of your membership on tgl279.
- Closed account data: Following account closure, tgl279 retains identity data, KYC documents, and transaction records for a period of five (5) years to satisfy AML record-keeping requirements under our international gaming licence.
- Support communications: Live chat transcripts and email correspondence are retained for two (2) years from the date of the interaction for dispute resolution and quality assurance purposes.
- Technical and behavioural logs: Server access logs and session data are retained for twelve (12) months and are then automatically purged or anonymised.
- Marketing consent records: Records of your marketing consent or withdrawal of consent are retained for the duration of your membership plus one (1) year after account closure to demonstrate compliance.
At the end of each applicable retention period, Personal Data is either securely and permanently deleted from tgl279's systems or irreversibly anonymised so that it can no longer be linked to you as an individual.
Section 10
Your Privacy Rights
Subject to applicable law and certain conditions, you have the following rights in relation to the Personal Data tgl279 holds about you:
- Right of access: You may request a copy of all Personal Data tgl279 holds about you. tgl279 will provide this within 30 calendar days of a valid request.
- Right to rectification: If any Personal Data tgl279 holds about you is inaccurate or incomplete, you have the right to request that it be corrected. You may update basic contact details directly through your Account settings; for KYC-related corrections, please contact our support team.
- Right to erasure: You may request deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where processing is unlawful. This right is subject to tgl279's overriding legal obligations to retain certain data (e.g., AML records) — in such cases, we will restrict processing to the legally required minimum rather than deleting the data outright.
- Right to restrict processing: You may request that tgl279 pause the processing of your Personal Data in certain circumstances, such as while a rectification request is being assessed.
- Right to data portability: You may request a structured, machine-readable copy of the Personal Data you provided to tgl279, for the purpose of transferring it to another service provider.
- Right to withdraw consent: Where tgl279 processes your data on the basis of consent (e.g., marketing communications), you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing that occurred prior to withdrawal.
- Right to object: You may object to processing carried out on the basis of tgl279's legitimate interests. tgl279 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
To exercise any of these rights, please contact our support team using the email address listed in Section 14 below. We will respond to all privacy rights requests within 30 calendar days. Where a request is complex or involves a high volume of data, we may extend this period by a further 30 days — in which case we will notify you of the extension and the reason for it.
Section 11
Children's Privacy
The tgl279 Platform is strictly intended for adults aged 21 years or older. tgl279 does not knowingly collect Personal Data from individuals under the age of 21. If we discover or are notified that we have inadvertently collected Personal Data from an individual who was under 21 at the time of collection, we will immediately close the relevant Account, delete all associated Personal Data, and void any balances in accordance with our Terms & Conditions.
If you are a parent or guardian and you believe that a person under the age of 21 in your care has created an account on tgl279, please contact our support team immediately at the address in Section 14. We take underage access extremely seriously and will act on such reports without delay.
Section 12
International Data Transfers
tgl279 operates as an internationally licensed platform. As a result, your Personal Data may be processed and stored on servers located outside Indonesia. When transferring Personal Data to servers or service providers in jurisdictions outside Indonesia, tgl279 takes the following safeguards to ensure an adequate level of protection:
- Contractual data processing agreements that impose data protection obligations on the recipient equivalent to those described in this Policy.
- Selection of cloud infrastructure and third-party service providers that maintain internationally recognised security certifications (e.g., ISO 27001, SOC 2 Type II).
- Transfer only of the minimum data necessary to perform the relevant service — for example, game studio partners receive only a pseudonymous session token, not your full identity profile.
By using the tgl279 Platform, you acknowledge that your Personal Data may be transferred to and processed in countries outside Indonesia, and you consent to such transfers being made in accordance with the safeguards described in this section.
Section 13
Amendments to This Policy
tgl279 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, regulatory guidance, or platform features. When we make material changes to this Policy — for example, introducing a new category of data collection or a new third-party sharing arrangement — we will notify active Members by email to the address registered on their Account at least 7 days before the change takes effect.
The "Last Updated" date at the top of this page will be revised each time the Policy is amended. We recommend that Members review this page periodically. Your continued use of the Platform after the effective date of any amendment constitutes acceptance of the updated Policy. If you do not agree to the amended Policy, you should cease using the Platform and request account closure through our support team.
Section 14
Contact & Privacy Complaints
If you have any questions about this Privacy Policy, wish to exercise your privacy rights, or want to raise a concern about how tgl279 handles your Personal Data, please contact our Data Protection team through the following channel:
- Email: [email protected] (plain text — not a clickable link)
- Subject line: Please use "Privacy Request — [Your Username]" to ensure your message is routed to the correct team
- Response time: Privacy-related enquiries are treated as high priority and will receive an initial response within 3 business days. Full resolution will be completed within 30 calendar days.
- Live chat: Available on the Platform from 06:00–24:00 WIB, 7 days a week, for urgent privacy or account security concerns
If you are not satisfied with tgl279's response to your privacy complaint, you have the right to escalate the matter to the data protection supervisory authority in the jurisdiction where tgl279 holds its international gaming licence, or to seek independent legal advice.