Privacy Policy — 789apk

1 Data Controller

789apk acts as the data controller in respect of all personal data collected from its members. As data controller, 789apk determines the purposes for which personal data is processed and the means by which that processing is carried out.

For all privacy-related enquiries, data subject access requests, correction requests, and complaints, members may contact 789apk's dedicated data privacy team using the contact details provided in Clause 15 of this Policy.

2 Personal Data We Collect

789apk collects the following categories of personal data from members and prospective members. Collection occurs at registration, during ongoing account use, and as part of identity verification (KYC) and financial compliance processes.

3 How We Collect Personal Data

789apk collects personal data through the following channels and mechanisms:

• Directly from you: When you complete the member registration form, submit KYC verification documents, make a deposit or withdrawal request, contact the support team, or update your account profile settings.
• Automatically during platform use: Technical and device data, usage patterns, and behavioural data are collected automatically by the platform's analytics and security infrastructure each time you log in and interact with the site. This includes data collected via cookies and similar tracking technologies (see Clause 7).
• From payment processors and financial institutions: When you initiate a deposit or withdrawal, 789apk's payment processing partners (including local Indonesian bank transfer networks and e-wallet providers) transmit transaction confirmation data to the platform. This may include the sender account number, transaction reference, and amount confirmed.
• From identity verification partners: During KYC processing, 789apk may engage third-party identity verification services that cross-reference the documents you submit against external databases to confirm authenticity. These partners operate under strict confidentiality agreements.
• From fraud and risk management systems: Automated systems monitor account and transaction activity for patterns associated with fraud, money laundering, or Terms violations. These systems may process and flag data based on behavioural signals across your account history.

4 How We Use Your Personal Data

789apk uses the personal data it collects for the following specific and documented purposes:

1. Account creation and management: To register your member account, authenticate your identity at login, maintain your account settings, and manage your balance and transaction history.
2. Payment processing: To process deposits and withdrawal requests through your selected Indonesian payment channel (local bank transfer or e-wallet), verify that payment accounts belong to you, and maintain accurate financial records in IDR.
3. Identity verification (KYC) and regulatory compliance: To verify that you meet the minimum age requirement of 21 years, confirm your identity and residential address, and comply with Anti-Money Laundering (AML) and counter-terrorist financing obligations applicable to our operating licence.
4. Provision of gaming and betting services: To process your bets and wagers, deliver game results, calculate and credit winnings, apply bonus credits, and maintain a complete record of your gaming history on 789apk.
5. Platform security and fraud prevention: To detect and prevent unauthorised account access, identify multi-account violations, flag suspicious transaction patterns, and investigate potential Terms violations including bonus abuse and money laundering.
6. Customer support: To respond to your support enquiries via live chat and email, resolve account disputes, and maintain records of support interactions for quality assurance and training purposes.
7. Responsible gaming: To monitor gaming patterns that may indicate problem gambling behaviour, to apply self-imposed deposit limits or cooling-off periods you have requested, and to respond appropriately if our systems or your own disclosures indicate that gambling is causing you harm.
8. Marketing communications (where consented): To send you promotional offers, bonus notifications, and platform updates by email, where you have explicitly opted in to receive such communications. You may withdraw marketing consent at any time via your account settings.
9. Platform improvement and analytics: To analyse aggregated usage patterns, identify usability issues, optimise page performance, and inform product development decisions. Analytics processing uses pseudonymised or aggregated data wherever possible.

5 Legal Basis for Processing

Each processing activity carried out by 789apk rests on one or more of the following recognised legal bases:

• Contractual necessity: Processing required to fulfil our obligations to you under the 789apk Terms & Conditions — including account management, payment processing, bet settlement, and customer support — is carried out on the basis of contractual necessity. Without this processing, we cannot provide the service.
• Legal obligation: Processing required to comply with AML regulations, KYC obligations, regulatory reporting duties, and applicable financial crime prevention laws is carried out on the basis of legal obligation. This processing cannot be opted out of.
• Legitimate interests: Processing for fraud prevention, platform security monitoring, abuse detection, and internal analytics is carried out on the basis of 789apk's legitimate interest in operating a secure and commercially viable platform. We apply a balancing test to ensure this processing does not override members' fundamental privacy interests.
• Consent: Marketing communications and certain optional analytics cookies are processed on the basis of your explicit, freely given consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

6 Data Sharing & Third-Party Disclosure

789apk does not sell your personal data. We share personal data only in the following circumstances and only with parties bound by appropriate confidentiality and data protection obligations:

• Payment processors and financial institutions: Transaction data is shared with the relevant Indonesian bank networks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata), e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja), and card schemes (Visa, Mastercard) to the extent necessary to execute and confirm your deposit and withdrawal transactions.
• Identity verification providers: KYC document data may be transmitted to our contracted identity verification partner(s) solely for the purpose of verifying your identity and age in connection with account compliance. These partners are prohibited from using your data for any other purpose.
• Game content providers: Limited session data (e.g., player ID, bet amount, game result) is shared with our licensed game studio partners — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft — to the extent necessary to deliver and settle the game round in real time. These providers are contractually bound to handle this data in accordance with their own privacy policies and applicable data protection standards.
• Fraud and risk management services: Aggregated and pseudonymised behavioural signals may be shared with third-party fraud detection services to identify known patterns of abuse across the industry.
• Regulatory and law enforcement authorities: 789apk will disclose personal data to competent regulatory authorities, law enforcement agencies, or courts when required to do so by law, by valid legal process, or to protect the legal rights of 789apk or its members.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of 789apk's assets, personal data held about members may be transferred to the acquiring entity. Members will be notified in advance of any such transfer and of any change in the applicable privacy policy.

7 Cookies & Tracking Technologies

789apk uses cookies and similar client-side technologies to deliver a functional, secure, and personalised platform experience. The following categories of cookies are used:

• Strictly necessary cookies: These cookies are essential for the platform to function. They manage your authenticated session, maintain your account security token, remember your currency and language preferences within the platform, and enable core features such as the bet slip and account balance display. These cookies cannot be disabled without breaking core functionality.
• Performance and analytics cookies: These cookies collect pseudonymised data about how members navigate and use the platform — including pages visited, features accessed, error events, and session duration. This data is used exclusively to improve platform performance and usability. No personally identifiable information is included in analytics reports.
• Functionality cookies: These cookies remember your optional preferences — such as your preferred game lobby view, last-visited game category, and notification settings — so that these choices persist across sessions without requiring you to reconfigure them each time you log in.
• Fraud-prevention and security cookies: These cookies assist in identifying and blocking bots, brute-force login attempts, and other automated abuse patterns by analysing device and session fingerprinting signals.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from being able to log in to and use your 789apk account.

8 Data Retention

789apk retains personal data for the minimum period necessary to fulfil its stated collection purpose, after which data is securely deleted or irreversibly anonymised. The following standard retention periods apply:

• Active account data: Retained for the full duration of your membership with 789apk, plus a minimum of 5 years after the date of account closure, to satisfy AML record-keeping requirements.
• KYC and identity documents: Retained for a minimum of 5 years from the date of account closure. Where a compliance investigation is ongoing, relevant documents are retained until the investigation is formally concluded.
• Transaction records (deposits and withdrawals): Retained for a minimum of 5 years from the date of each transaction to comply with financial crime prevention regulations.
• Betting and gaming history: Retained for a minimum of 3 years from the date of each event, and for the full duration of any active dispute or investigation period extending beyond that.
• Support communications: Live chat transcripts and email correspondence are retained for 2 years from the date of the interaction, unless they are relevant to an unresolved dispute, in which case they are retained until resolution.
• Marketing consent records: Retained for 5 years from the date of consent, or until consent is withdrawn, whichever is earlier. Withdrawal of consent does not affect the retention of the consent record itself.
• Analytics data: Aggregated and pseudonymised analytics data may be retained for up to 3 years to support long-term platform improvement analysis.

9 Data Security

789apk implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, loss, alteration, or disclosure:

• Encryption: All data transmitted between your device and the 789apk platform is encrypted using TLS 1.3. All personal and financial data stored in our databases is encrypted at rest using AES-256.
• Access controls: Access to personal data within 789apk's internal systems is restricted on a strict need-to-know basis. Staff access is governed by role-based permissions, and all access events are logged and audited.
• Password security: Member passwords are stored as salted hashes using a modern cryptographic algorithm. Plain-text passwords are never stored at any point in the system. 789apk staff will never ask you for your password.
• Two-factor authentication (2FA): 789apk supports optional two-factor authentication on member accounts as an additional layer of login security. Members are encouraged to enable 2FA from their account settings.
• Penetration testing: The 789apk platform undergoes regular independent security testing to identify and remediate vulnerabilities before they can be exploited.
• Incident response: In the event of a confirmed personal data breach that is likely to result in a risk to affected members, 789apk will notify impacted members via their registered email address within 72 hours of becoming aware of the breach, detailing the nature of the incident and the steps being taken to address it.

10 Your Privacy Rights

As a 789apk member, you hold the following rights in respect of your personal data. These rights may be exercised by contacting the 789apk data privacy team at the email address provided in Clause 15:

All rights requests will be acknowledged within 2 business days and responded to substantively within 10 business days. Where a request is complex or where we receive a high volume of requests simultaneously, we may extend the response period by a further 10 business days, with prior notice to you.

11 Minors & Age Restriction

789apk's services are strictly restricted to individuals who are 21 years of age or older. The platform is not directed at, and does not knowingly collect personal data from, any person under the age of 21.

If you are a parent or guardian and you become aware that a person under the age of 21 has registered an account on 789apk using false information, please contact our support team immediately at the email address in Clause 15. We will investigate promptly, close the account, and permanently delete all personal data associated with the underage registration, except where retention is required by law.

12 Third-Party Services & External Links

The 789apk platform integrates third-party game content from licensed studio partners including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft. When you launch a game provided by one of these studios, a direct session is established between your browser and the studio's game server. The studio will process certain session data (player session token, bet and result data) in accordance with its own privacy policy. 789apk is not responsible for the data practices of third-party game studio servers once a direct session is established.

The 789apk platform does not contain links to external websites outside of the 789apk domain. If you encounter a link purporting to lead to an external third-party website from within the 789apk platform, please report it to our support team as this may indicate a security anomaly or phishing attempt.

13 Cross-Border Data Transfers

In order to deliver the 789apk platform to Indonesian players, certain personal data may be transferred to and processed on servers located outside of Indonesia. Specifically, data may be processed in jurisdictions where our infrastructure providers, KYC partners, or game studio partners maintain data centres.

Where such transfers occur, 789apk ensures that appropriate safeguards are in place to protect your data to a standard equivalent to the protections described in this Policy. These safeguards include:

• Contractual data processing agreements incorporating internationally recognised model clauses that require the recipient to process data only for permitted purposes and to maintain equivalent security standards.
• Technical controls including end-to-end encryption of data in transit to ensure that data cannot be intercepted or read during transfer between jurisdictions.
• Vendor due diligence processes that assess the data protection practices of all third-party processors before they are engaged and on a periodic basis thereafter.

14 Amendments to This Policy

789apk reserves the right to update or revise this Privacy Policy at any time. When material changes are made — for example, changes to the categories of data collected, the purposes of processing, or the third parties with whom data is shared — registered members will be notified via email at least 7 days before the revised Policy takes effect.

Minor, non-material updates (such as clarifications of existing language that do not change the substantive meaning) may be made without advance notice; the "Last Reviewed" date at the top of this page will be updated to reflect the revision date.

Your continued use of the 789apk platform after the effective date of a revised Privacy Policy constitutes your acknowledgement and acceptance of the updated terms. If you do not accept the revised Policy, you must close your account before the effective date by contacting the support team.

15 Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise any of your privacy rights, or wish to make a complaint about how 789apk has handled your personal data, please contact our data privacy team using the details below:

When submitting a data subject rights request, please include your registered email address, the specific right you wish to exercise, and any relevant details that will help us locate and process your request efficiently. We may ask you to verify your identity before processing the request to ensure we do not disclose data to an unauthorised party.

If you are not satisfied with our response to your complaint, you may escalate the matter to the relevant supervisory or regulatory authority in your jurisdiction.