Privacy Policy

1. Introduction

dana89 ("we", "us", "our") operates the online betting and casino platform accessible at https://dana89.cam (the "Platform"). This Privacy Policy describes how dana89 collects, processes, stores, discloses, and protects personal data submitted by or collected from individuals who register for and use the Platform ("Players" or "you").

By registering an account on dana89 or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with the practices described in this Policy, you should not use the Platform.

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 but not limited to name, identification number, location data, online identifier, or 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, organization, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, alignment, restriction, erasure, or destruction.
• "Data Controller" means dana89, the entity that determines the purposes and means of processing personal data collected through the Platform.
• "Data Processor" means any third party that processes personal data on behalf of dana89 under a contractual data processing agreement.
• "KYC" means Know Your Customer — the identity verification process conducted by dana89 to satisfy its anti-money-laundering and responsible gaming obligations.
• "Cookie" means a small data file placed on your device by the Platform to store session information and usage preferences.
• "Consent" means any freely given, specific, informed, and unambiguous indication of your agreement to the processing of your personal data for a stated purpose.

3. Personal Data We Collect

dana89 collects personal data across several categories depending on how you interact with the Platform. The table below summarizes the key categories and specific data points collected:

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, or health data beyond what is strictly necessary for responsible gaming compliance (e.g., self-exclusion records and problem gambling indicators).

4. How We Collect Personal Data

dana89 collects personal data through the following channels and mechanisms:

• Direct submission: Data you provide actively when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or submitting a formal complaint.
• Automated technical collection: Data collected passively as you use the Platform, including device identifiers, IP address logs, session cookies, clickstream data, and browser fingerprinting used to detect fraud and unauthorized access.
• Third-party payment processors: Transaction confirmation data received from partner banks (BCA, BRI, BNI, Mandiri, and others) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) when you initiate a deposit or withdrawal.
• Identity verification services: Where dana89 uses third-party KYC verification providers, those providers may return identity match scores and document authenticity results to dana89 in connection with the processing of your KYC submission.
• Publicly available sources: In limited circumstances relating to AML compliance, dana89 may cross-reference submitted data against publicly available sanctions lists, politically exposed persons (PEP) databases, and adverse media sources.

5. Purposes of Processing

dana89 processes your personal data for the following specific, legitimate purposes:

1. Account management: Creating, maintaining, and administering your player account, including authentication and security monitoring.
2. Service delivery: Enabling you to place bets, play casino games, participate in togel draws, and access all Platform features in Indonesian Rupiah (IDR).
3. Payment processing: Facilitating IDR deposits and withdrawals through your nominated bank account or e-wallet.
4. Identity verification (KYC): Confirming your identity and age (21+) in compliance with our gaming license obligations and applicable AML requirements.
5. Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, bonus abuse, and other security incidents.
6. Regulatory compliance: Meeting record-keeping, reporting, and audit obligations imposed by our international gaming license and applicable financial crime prevention regulations.
7. Responsible gaming: Monitoring account activity to identify patterns indicative of problem gambling and administering self-exclusion requests, deposit limits, and session controls.
8. Customer support: Responding to inquiries, resolving disputes, and providing technical assistance.
9. Personalization: Tailoring promotional offers, game recommendations, and Platform content to your stated preferences and usage patterns, where you have given consent.
10. Marketing communications: Sending promotional emails or SMS messages regarding bonuses, new games, and seasonal events (Idul Fitri, Ramadan promotions, Indonesian Independence Day specials), where you have opted in.
11. Platform improvement: Analyzing aggregated usage data to improve Platform performance, game selection, and user experience.

6. Legal Basis for Processing

dana89 relies on the following legal bases for processing your personal data, depending on the specific purpose involved:

• Contractual necessity: Processing is necessary to perform the contract between you and dana89, including account creation, service delivery, payment processing, and customer support.
• Legal obligation: Processing is required to satisfy our obligations under our gaming license, AML regulations, tax reporting requirements, and responsible gaming duties.
• Legitimate interests: Processing is necessary for our legitimate business interests in fraud prevention, security monitoring, platform optimization, and enforcement of our Terms & Conditions, provided those interests are not overridden by your fundamental rights.
• Consent: Where you have explicitly consented to specific processing activities, such as marketing communications or optional data collection for personalization features. Consent may be withdrawn at any time.

7. Data Sharing & Third-Party Disclosure

dana89 does not sell or rent your personal data to third-party marketing companies. However, we may share your data with the following categories of recipients where necessary for the purposes outlined in this Policy:

• Payment service providers: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) receive transaction data necessary to process deposits and withdrawals.
• KYC verification providers: Specialized third-party identity verification services may receive copies of your KTP, proof of address, and selfie photograph to conduct automated or manual identity checks on dana89's behalf.
• Gaming platform providers: Game studios and live casino providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft) receive your username and session identifiers to enable gameplay but do not receive full personal or financial details.
• Customer support tools: Cloud-based live chat and email support platforms used by dana89 may process communications data and account identifiers to facilitate customer service.
• Regulatory authorities: dana89 is legally required to disclose certain records to the licensing authority that oversees our operations and to financial intelligence units in connection with AML investigations.
• Legal advisors and law enforcement: We may disclose data to legal counsel in connection with disputes, litigation, or to law enforcement agencies where required by court order, subpoena, or applicable law.
• Business successors: In the event of a merger, acquisition, or asset sale, player data may be transferred to the successor entity, subject to this Privacy Policy remaining in effect.

All third-party data processors engaged by dana89 are bound by strict contractual data protection obligations that require them to process data solely on dana89's instructions and to maintain adequate security measures.

8. Data Retention

dana89 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable legal and regulatory obligations. Specific retention periods are as follows:

• Account data: Retained for the duration of your active account plus 7 years following account closure to satisfy our gaming license record-keeping requirements.
• Transactional data: Betting and gaming records, deposit/withdrawal logs, and financial statements are retained for 7 years after the relevant transaction to meet AML and tax reporting obligations.
• KYC documentation: Identity documents are retained for 7 years following the last account activity or final transaction, whichever is later, in accordance with AML regulations.
• Communications logs: Customer support transcripts, email correspondence, and dispute records are retained for 3 years for quality assurance and dispute resolution purposes.
• Marketing data: If you opt out of marketing communications, your opt-out preference is retained indefinitely to ensure we do not inadvertently re-contact you.
• Self-exclusion records: Records of self-exclusion requests and problem gambling indicators are retained indefinitely to ensure permanent exclusions are enforced and to protect vulnerable players.

At the expiry of the applicable retention period, personal data is securely deleted or anonymized such that it can no longer identify you. Anonymized aggregated data may be retained indefinitely for statistical analysis.

9. Data Security Measures

dana89 implements technical and organizational security measures designed to protect your personal data against unauthorized or unlawful processing, accidental loss, destruction, or damage. Key security controls include:

• Encryption in transit: All data transmitted between your device and dana89 servers is encrypted using 256-bit SSL/TLS protocols, ensuring that login credentials, financial details, and personal information cannot be intercepted.
• Encryption at rest: Sensitive personal data, including KYC documents and financial records, is stored in encrypted form on access-controlled servers.
• Access control: Physical and logical access to player data is restricted to authorized dana89 personnel on a strict need-to-know basis. Role-based access controls and multi-factor authentication are enforced.
• Intrusion detection: Real-time monitoring systems detect and alert our security team to unauthorized access attempts, malware, and other security incidents.
• Regular audits: Security controls are audited periodically by internal compliance teams and external security assessors to ensure ongoing effectiveness.
• Employee training: All dana89 staff with access to personal data receive mandatory training on data protection principles, confidentiality obligations, and incident response protocols.

10. Cookies & Tracking Technologies

dana89 uses cookies and similar tracking technologies to enhance Platform functionality, personalize your experience, and collect usage analytics. A cookie is a small text file stored on your device that allows the Platform to recognize your browser across sessions.

We deploy the following types of cookies:

• Strictly necessary cookies: These enable core Platform functions such as user authentication, session management, and security. The Platform cannot function properly without these cookies.
• Performance cookies: These collect anonymous information about how visitors use the Platform (e.g., most visited pages, error messages) to help us improve site performance and user experience.
• Functionality cookies: These remember your preferences (e.g., language selection, display currency IDR) to personalize your experience.
• Targeting cookies: These track your activity across sessions to deliver personalized promotional offers and measure the effectiveness of marketing campaigns. These are only used where you have given explicit consent.

You may refuse or delete cookies through your browser settings. However, disabling strictly necessary cookies will prevent you from accessing certain Platform features, including account login and gameplay.

11. Your Data Protection Rights

You hold the following rights in relation to the personal data that dana89 processes about you:

• Right of access: You may request a copy of all personal data dana89 holds about you. We will provide this information in a structured, commonly used electronic format within 30 days of your request.
• Right to rectification: If any of your personal data is inaccurate or incomplete, you have the right to request correction. You may update certain data directly via your account settings.
• Right to erasure (right to be forgotten): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent, or where you object to processing. This right is subject to legal retention obligations (see Data Retention section).
• Right to restriction of processing: You may request that dana89 limit processing of your data in certain circumstances, such as while a dispute over data accuracy is resolved.
• Right to data portability: You have the right to receive your personal data in a machine-readable format and to transmit it to another service provider where technically feasible.
• Right to object: You may object to processing based on legitimate interests or for direct marketing purposes. Upon receipt of an objection to marketing, dana89 will cease such processing immediately.
• Right to withdraw consent: Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of prior processing.
• Right to lodge a complaint: If you believe dana89 has processed your data unlawfully, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.

To exercise any of these rights, contact dana89 support at [email protected] with your registered username and a clear description of your request. We will respond within 30 days of verifying your identity.

12. Protection of Minors

The dana89 Platform is strictly intended for adults aged 21 years or older. dana89 does not knowingly collect, process, or retain personal data from individuals under the age of 21. Age verification is a mandatory component of the KYC process, and any account found to belong to a person under 21 will be closed immediately.

If we become aware that we have inadvertently collected data from a minor, that data will be deleted from our systems as soon as reasonably practicable. If you believe dana89 holds data relating to a minor, please contact us immediately at [email protected].

13. International Data Transfers

dana89 operates under an international gaming license and may process or store your personal data on servers located outside Indonesia. Where data is transferred to jurisdictions that do not provide an equivalent level of data protection to Indonesia, dana89 implements appropriate safeguards including:

• Standard contractual clauses approved by recognized data protection authorities
• Binding corporate rules governing intra-group data transfers
• Adequacy decisions recognizing the recipient jurisdiction as providing adequate protection

By using the Platform, you acknowledge and consent to the transfer of your data outside Indonesia for the purposes described in this Policy.

14. Amendments to This Privacy Policy

dana89 reserves the right to amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or Platform features. Material changes will be communicated to registered players via email or in-platform notification at least 14 days before the revised Policy takes effect.

The revised Policy will display an updated "Last Updated" date at the top of this page. Your continued use of the Platform following the effective date of an amended Policy constitutes acceptance of the revised terms. If you do not agree with the amendments, you should cease using the Platform and may request account closure.

15. Contact Information

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact the dana89 Data Protection Officer:

When contacting us regarding a data subject request (access, rectification, erasure, etc.), please include your registered username and sufficient information to verify your identity. We may request additional proof of identity before processing requests that involve disclosure or deletion of personal data.