Privacy Policy

1Definitions

In this Privacy Policy, the following terms carry the meanings set out below:

• "Platform" means the kop92 website accessible at kop92.cam and any associated mobile-optimized interface.
• "We," "Us," "Our," and "kop92" refer to the operator of the Platform and the data controller responsible for your personal data.
• "You," "User," and "Player" refer to any individual who accesses, registers on, or interacts with the Platform.
• "Personal Data" means any information that identifies or can reasonably be used to identify you as an individual, including your name, email address, date of birth, bank account details, IP address, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, and deletion.
• "KYC" means Know Your Customer identity and document verification procedures required before account activation and withdrawal processing.
• "Third-Party Service Provider" means any external company engaged by kop92 to deliver specific services, including payment processing, identity verification, customer support, and analytics.
• "Cookies" means small data files placed on your device by the Platform to store session information, preferences, and analytical data.

2Scope and Applicability

This Privacy Policy applies to all Personal Data collected by kop92 in connection with the operation of the Platform, including data collected during account registration, KYC verification, deposits, withdrawals, gameplay, customer support interactions, and voluntary communications you initiate with us.

This policy applies to all users of the Platform regardless of geographic location, but is specifically designed with the rights and expectations of Indonesian players in mind, acknowledging Indonesia's evolving data protection landscape and the requirements of the Indonesian Personal Data Protection Law (UU PDP) where applicable.

By creating an account on the Platform, you acknowledge that you have read this Privacy Policy in full and consent to the collection and processing of your Personal Data as described herein. If you do not agree with this policy, you should refrain from using the Platform and request account closure.

3Data We Collect

kop92 collects the following categories of Personal Data in the course of providing its services:

3.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (to verify that you are 21 years of age or older);
• Residential address in Indonesia or your country of residence;
• Email address and mobile telephone number;
• Nationality and country of residence.

3.2 Identity Verification (KYC) Data

• Scanned copy or photograph of your Indonesian KTP (National Identity Card), passport, or other government-issued photo identification;
• Proof of residential address (utility bill, bank statement, or equivalent official document dated within three months);
• Selfie photograph taken alongside your identity document;
• Where required: source-of-funds documentation and enhanced due diligence materials.

3.3 Financial Data

• Bank account details including account holder name, bank name (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, or Bank Permata), and account number;
• E-wallet identifiers for OVO, DANA, GoPay, ShopeePay, or LinkAja where used;
• Transaction history including deposit amounts, withdrawal amounts, dates, and payment method used;
• Wagering history including bet amounts, game types, and outcomes.

3.4 Technical and Usage Data

• IP address and approximate geographic location derived therefrom;
• Device type, operating system, and browser type and version;
• Session duration, pages visited, features used, and clickstream data;
• Login timestamps and access logs;
• Cookie identifiers and similar tracking data (see Clause 9).

3.5 Communications Data

• Records of all communications between you and our customer support team, whether via live chat, email, or any other channel;
• Feedback, survey responses, and voluntary information you provide when contacting us.

4How We Collect Your Data

kop92 collects Personal Data through the following methods:

4.1 Direct Collection

Data you provide directly when registering an account, completing KYC verification, making a deposit or withdrawal request, placing a wager, contacting customer support, or responding to surveys and promotions. This constitutes the primary source of your Personal Data in our systems.

4.2 Automated Collection

Data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, server logs, and similar technologies. This data is collected as a standard feature of internet-based services and is used for platform security, fraud prevention, and user experience optimization.

4.3 Third-Party Sources

In certain circumstances, kop92 may receive data about you from third parties, including:

• Identity verification service providers who confirm the authenticity of your KYC documents;
• Payment processors who confirm the status and legitimacy of financial transactions;
• Fraud prevention databases that flag patterns associated with known fraudulent activity;
• Publicly available sources such as government sanction lists used for regulatory compliance checks.

5Purposes and Legal Basis for Processing

kop92 processes your Personal Data only where a legitimate legal basis exists for doing so. The table below summarises the primary purposes for which we process your data and the corresponding legal basis:

Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. Withdrawal of consent for optional processing (such as marketing communications) will not impair your ability to use the Platform.

6Data Sharing and Disclosure

kop92 does not sell, rent, or trade your Personal Data. We share your data only in the limited circumstances described below, and only to the extent strictly necessary for the stated purpose:

6.1 Payment Processors

To facilitate deposits and withdrawals via BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, OVO, DANA, GoPay, and other supported payment methods, we share the minimum necessary financial and identity data with the relevant payment service providers. These providers are bound by their own regulatory obligations and contractual data protection commitments.

6.2 Identity Verification Providers

KYC document verification is conducted by accredited third-party identity verification providers. Your identity documents and selfie photographs are transmitted to these providers via encrypted channels solely for verification purposes and are not retained by them beyond the verification lifecycle.

6.3 Fraud Prevention and Security Services

We share technical and behavioural data with specialist fraud prevention and cybersecurity service providers who help us detect and prevent account takeovers, payment fraud, and other malicious activity. This sharing is carried out under legitimate interest grounds and is subject to strict data processing agreements.

6.4 Legal and Regulatory Authorities

kop92 may disclose Personal Data to government authorities, law enforcement agencies, or regulatory bodies where required to do so by applicable law, valid legal process, court order, or in connection with the investigation of suspected criminal activity including money laundering, fraud, or terrorist financing. In such cases, we will disclose only the minimum data required to satisfy the legal obligation.

6.5 Corporate Transactions

In the event that kop92 undergoes a merger, acquisition, asset sale, or corporate restructuring, your Personal Data may be transferred to the successor entity as part of that transaction. You will be notified of any such transfer and of any change to the privacy terms governing your data before it takes effect.

7International Data Transfers

kop92 operates internationally, and your Personal Data may be transferred to, stored on, and processed by servers or service providers located outside of Indonesia. Where such transfers occur, kop92 ensures that appropriate safeguards are in place to maintain a standard of protection equivalent to that provided under applicable Indonesian data protection law.

Safeguards we employ for international transfers include:

• Standard contractual clauses that bind recipient entities to equivalent data protection obligations;
• Transfers only to jurisdictions that maintain recognised adequacy standards for data protection;
• Encryption of data in transit and at rest regardless of the jurisdiction in which it is stored;
• Regular audits of third-party data processors to verify ongoing compliance with our security requirements.

By using the kop92 Platform, you acknowledge and consent to the transfer of your Personal Data outside Indonesia under the safeguards described above.

8Data Retention

kop92 retains your Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, to comply with legal and regulatory obligations, and to resolve any disputes or enforce our agreements. The following indicative retention periods apply:

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised so that it can no longer be associated with any identifiable individual. Anonymised aggregated data may be retained indefinitely for analytical and statistical purposes.

9Cookies and Tracking Technologies

kop92 uses cookies and similar tracking technologies to operate the Platform effectively, maintain your session, remember your preferences, detect fraud, and gather analytical data that helps us improve our services.

9.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled without impairing Platform functionality.
• Functional Cookies: Store your preferences such as language settings, default deposit method, and display preferences to provide a more personalised experience.
• Analytical Cookies: Help us understand how users navigate the Platform, which pages generate the most engagement, and where technical errors occur. Data collected is aggregated and does not identify individual users.
• Security and Fraud-Prevention Cookies: Enable our systems to recognise your device across sessions, detect anomalous login behaviour, and flag potentially fraudulent activity for review.

9.2 Managing Cookies

You may manage cookie preferences through your browser settings. Most modern browsers allow you to view, block, or delete cookies at any time. Please note that disabling strictly necessary cookies will prevent you from logging in or using core Platform features. Disabling functional or analytical cookies will not affect your ability to place bets or conduct transactions.

10Children's Privacy

The kop92 Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect, process, or store Personal Data from any person under 21 years of age. Age verification is a mandatory step in our account registration and KYC processes.

If kop92 becomes aware that Personal Data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete all collected data to the extent permitted by our legal obligations, and notify the relevant authorities where appropriate. If you believe a minor has registered an account on the Platform, please contact our support team immediately at [email protected].

11Security Measures

kop92 implements a comprehensive set of technical and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS Encryption: All data transmitted between your browser or device and our servers is encrypted using industry-standard Transport Layer Security protocols;
• AES-256 Encryption at Rest: Sensitive data stored in our databases is encrypted using AES-256 encryption, the same standard employed by major international banks;
• Access Controls: Access to Personal Data is restricted on a strict need-to-know basis. Staff with access undergo regular background checks and security training;
• Two-Factor Authentication (2FA): Available and strongly recommended for all kop92 accounts to protect against unauthorised login;
• Regular Security Audits: Our infrastructure and application security are assessed regularly through independent penetration testing and vulnerability scanning;
• Incident Response Plan: kop92 maintains a documented data breach response procedure. In the event of a breach affecting your data, we will notify you and relevant authorities within the timeframes required by applicable law.

While we take every reasonable precaution to protect your data, no internet-based service can guarantee absolute security. You are encouraged to use a strong, unique password for your kop92 account and to enable two-factor authentication to maximise your account's protection.

12Your Rights as a Data Subject

As a user of the kop92 Platform, you hold the following rights with respect to your Personal Data. To exercise any of these rights, please submit a written request to our support team at the contact details provided in Clause 16. We will respond within 30 calendar days of receiving a valid request.

12.1 Right of Access

You have the right to request a copy of the Personal Data we hold about you, together with information about how that data is processed, the purposes for which it is used, and the categories of third parties with whom it has been shared.

12.2 Right to Rectification

If any Personal Data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected or updated. For certain data categories (such as your registered bank account details), correction may require submission of supporting documentation.

12.3 Right to Erasure

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 (for consent-based processing), or where you object to processing based on legitimate interest. Please note that certain data cannot be deleted where retention is required by law, such as KYC records and financial transaction data subject to AML retention obligations.

12.4 Right to Restrict Processing

You may request that we restrict the processing of your data in certain circumstances — for example, while the accuracy of data you have contested is being verified, or while an objection to processing is being assessed.

12.5 Right to Data Portability

Where processing is based on your consent or on contract performance and is carried out by automated means, you have the right to receive your Personal Data in a structured, commonly used, machine-readable format and to transmit that data to another controller.

12.6 Right to Object

You have the right to object at any time to the processing of your Personal Data where that processing is based on legitimate interest, including profiling carried out on that basis. You also have an unconditional right to object to processing for direct marketing purposes.

13Marketing Communications

kop92 may send you promotional communications about bonuses, special offers, new game releases, seasonal promotions (such as those tied to Idul Fitri, Ramadhan, or Indonesian Independence Day on 17 August), and platform updates. All marketing communications are sent exclusively on an opt-in basis.

13.1 Consent and Opt-In

During registration, you will be given a clear and separate opportunity to consent to receiving marketing communications by email, SMS, or in-platform notification. Opting in to marketing communications is entirely voluntary and has no bearing on your ability to register or use your account.

13.2 Withdrawing Consent

You may withdraw your consent to receive marketing communications at any time by:

• Using the unsubscribe link present in every marketing email we send;
• Updating your notification preferences in your account settings;
• Contacting our support team at [email protected] and requesting removal from all marketing lists.

Withdrawal of marketing consent will be actioned within 5 business days. Please note that transactional communications — such as deposit confirmations, withdrawal notifications, and security alerts — are not marketing communications and will continue to be sent regardless of your marketing preference.

14Amendments to This Policy

kop92 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform functionality. The date of the most recent revision is displayed prominently at the top of this page.

Where changes are material — meaning they significantly affect how we use your Personal Data or the rights available to you — we will provide advance notice by email to your registered address no fewer than 14 days before the changes take effect. For non-material updates, the revised policy will be published on the Platform immediately upon revision.

Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not accept the revised terms, you should cease using the Platform and may request account closure and withdrawal of any remaining balance.

15Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the jurisdiction in which kop92 holds its international operating licence. Where Indonesian law imposes specific obligations on data controllers processing the Personal Data of Indonesian residents — including the requirements of Indonesia's Personal Data Protection Law (Undang-Undang Perlindungan Data Pribadi) — kop92 is committed to meeting those obligations to the fullest extent applicable.

Any dispute arising out of or in connection with this Privacy Policy that cannot be resolved informally through our support team shall be subject to the dispute resolution procedure set out in our Terms & Conditions.

16Contact and Data Requests

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your Personal Data, please contact our Data Protection team through any of the following channels:

• Email: [email protected] — please use the subject line "Privacy Request" for all data-related inquiries
• Live Chat: Available 24 hours a day, 7 days a week via the chat widget on the Platform
• Response Languages: English and Indonesian (Bahasa Indonesia) — native-speaking support agents are available around the clock
• Acknowledgement: All privacy-related requests will receive an acknowledgement within 5 business days (WIB, UTC+7)

For urgent matters — including suspected unauthorized access to your account, suspected data breach, or requests related to a minor's account — please mark your message as URGENT in the subject line and our team will prioritise your case accordingly.