Privacy Policy

1 Definitions

For the purposes of this Policy, the following terms carry the meanings set out below:

• "ind45" — the online gaming and sports betting platform operated at https://ind45.cam and all associated sub-domains and services. Also referred to as "we", "us", or "our".
• "User" / "you" — any individual who visits, registers on, or interacts with the ind45 platform, regardless of whether an account is created or a deposit is made.
• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, identification number, contact details, financial data, online identifiers, and location data.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, use, disclosure, transfer, deletion, or destruction.
• "Data Controller" — the entity that determines the purposes and means of Processing Personal Data. For users of ind45, the Data Controller is ind45.
• "Third Party" — any natural or legal person other than you, ind45, and ind45's direct service providers acting under our instruction.
• "Cookie" — a small text file placed on your device by a website to store information about your browsing session or preferences.
• "KYC" — Know Your Customer, the identity verification process required under anti-money laundering obligations.
• "Sensitive Data" — a subset of Personal Data requiring heightened protection, including identity document numbers, financial account details, and health information where voluntarily disclosed (e.g., in responsible gambling self-assessment).

2 Scope & Application

This Policy applies to all Personal Data collected by ind45 through:

• The ind45 website at https://ind45.cam and all associated sub-domains.
• Any official ind45 mobile application available on Android or iOS platforms.
• Customer support interactions via live chat, WhatsApp, email, and telephone.
• Marketing communications including email campaigns, SMS, and push notifications where you have opted in.
• KYC and payment verification processes.

This Policy is specifically drafted with reference to Indonesian data subjects and the Indonesian market context. ind45 serves players primarily located in Jakarta, Surabaya, Bandung, Medan, Bali, Yogyakarta, Semarang, Makassar, and other locations across Indonesia.

3 Data We Collect

ind45 collects the following categories of Personal Data, depending on how you interact with our platform:

We do not intentionally collect Sensitive Data beyond what is strictly necessary for identity verification (KTP or passport number) and responsible gaming purposes. We do not collect racial or ethnic origin, political opinions, religious beliefs, or biometric data beyond facial selfie verification used solely for identity confirmation.

4 How We Collect Data

4.1 Directly From You. The majority of Personal Data we hold is provided directly by you during account registration, profile updates, deposit and withdrawal requests, KYC submissions, and customer support interactions.

4.2 Automatically. When you visit the ind45 platform, we automatically collect Technical Data through server logs, cookies, pixel tags, and similar tracking technologies. This collection occurs even if you do not create an account.

4.3 From Payment Processors. When you make a deposit or withdrawal via Indonesian banks or e-wallets, our payment processing partners confirm transaction status and may share minimal financial data (e.g., account holder name match confirmation) necessary for fraud prevention.

4.4 From Identity Verification Services. During KYC, we may engage third-party identity verification providers who cross-reference the documents you submit against external databases to confirm authenticity.

4.5 From Anti-Fraud & Analytics Partners. We receive aggregated technical and behavioral signals from fraud detection services to identify potentially suspicious account activity.

5 Purposes of Processing

ind45 processes your Personal Data for the following specific, explicit, and legitimate purposes:

1. Account Management: Creating, maintaining, and securing your ind45 account; authenticating your identity at login; processing account closure requests.
2. Transaction Processing: Facilitating deposits in IDR via BCA, BRI, BNI, Mandiri, and other supported payment methods; processing withdrawals to your verified payment method; maintaining accurate financial records.
3. KYC & Regulatory Compliance: Verifying your age (you must be 21 or older), identity, and residential status in compliance with our operating license obligations and anti-money laundering requirements.
4. Gaming Services: Delivering sports betting markets, live casino tables, slot games, and specialty gaming products; calculating and crediting winnings; resolving betting disputes.
5. Customer Support: Responding to your inquiries via live chat, WhatsApp, and email; resolving technical issues; processing complaints.
6. Fraud Prevention & Security: Detecting and preventing unauthorized account access, multi-accounting, bonus abuse, money laundering, and other prohibited conduct.
7. Responsible Gaming: Monitoring gaming behavior to identify potential problem gambling indicators; administering self-exclusion, deposit limits, and session controls; providing access to responsible gaming resources.
8. Marketing & Promotions: Sending promotional offers, bonus notifications, and platform updates to users who have opted in; personalizing offers based on your gaming preferences and activity history.
9. Platform Improvement: Analyzing aggregated usage data to improve platform performance, user experience, game selection, and customer service quality.
10. Legal Obligations: Retaining records as required by our operating license conditions; responding to lawful requests from competent authorities.

6 Legal Basis for Processing

ind45 processes your Personal Data on one or more of the following legal bases, depending on the specific purpose:

• Contractual Necessity: Processing required to deliver the services you have requested by registering an account and accepting our Terms & Conditions — including account creation, transaction processing, and gaming services.
• Legal Obligation: Processing required to comply with applicable laws and our operating license conditions — including KYC verification, anti-money laundering checks, and age verification (21+ requirement).
• Legitimate Interests: Processing carried out to pursue our legitimate business interests, provided those interests do not override your fundamental rights — including fraud detection, platform security, and service improvement through aggregated analytics.
• Consent: Processing based on your freely given, specific, and informed consent — principally for direct marketing communications. You may withdraw consent at any time by updating your marketing preferences in your account settings or by contacting us at [email protected]. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

7 Data Sharing & Disclosure

7.1 Service Providers. ind45 engages carefully selected third-party service providers who process Personal Data on our behalf under binding data processing agreements. These categories include: payment gateway and banking partners (including integrations with BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja APIs); identity verification and KYC providers; cloud hosting and infrastructure providers; fraud detection and cybersecurity firms; game content providers (Pragmatic Play, Evolution Gaming, Spribe, Pocket Games Soft, NetEnt, Microgaming, and others); customer support platform operators; and email and communications service providers.

7.2 Regulatory Authorities. We may disclose Personal Data to competent regulatory, law enforcement, or governmental authorities when required by applicable law, valid court order, or our operating license conditions. We will notify you of such disclosure where legally permitted to do so.

7.3 Business Transfers. In the event of a merger, acquisition, asset sale, or corporate restructuring involving ind45, your Personal Data may be transferred to the acquiring entity, subject to equivalent privacy protections. You will be notified of any such transfer via your registered email address.

7.4 Responsible Gaming Partners. With your explicit consent, we may share limited data with licensed problem gambling support organizations to facilitate access to counseling or intervention services.

7.5 No Sale of Personal Data. ind45 does not sell, rent, or trade your Personal Data to third parties for their independent marketing or commercial purposes. Any data sharing is strictly limited to the purposes described in this Policy.

8 International Data Transfers

8.1 Cross-Border Processing. As an internationally operated platform, ind45 may store and process your Personal Data on servers located outside Indonesia. Where such transfers occur, we implement appropriate safeguards to ensure your data receives a level of protection consistent with internationally recognized data protection standards.

8.2 Safeguards. International transfers are protected through one or more of the following mechanisms: contractual clauses requiring the recipient to apply equivalent data protection standards; transfers only to jurisdictions with recognized adequate data protection frameworks; or explicit consent where no alternative safeguard applies.

8.3 Cloud Infrastructure. Our cloud hosting providers may operate data centers across multiple regions. All cloud providers engaged by ind45 are required to comply with our data security and privacy standards under contractual obligation.

9 Data Retention

ind45 retains Personal Data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law and our operating license conditions. The following standard retention periods apply:

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymized so that it can no longer be associated with any individual. Anonymized and aggregated data may be retained indefinitely for statistical and platform improvement purposes.

10 Security Measures

10.1 Technical Safeguards. ind45 implements a comprehensive suite of technical security controls designed to protect your Personal Data against unauthorized access, alteration, disclosure, or destruction:

• SSL/TLS Encryption: All data transmitted between your device and ind45 servers is encrypted using industry-standard SSL/TLS protocols. Look for the padlock icon in your browser address bar when visiting ind45.cam.
• At-Rest Encryption: Sensitive data stored on our servers, including financial records and identity documents, is encrypted at rest using AES-256 or equivalent standards.
• Two-Factor Authentication (2FA): We offer and encourage the use of two-factor authentication to add an additional layer of security to your account login.
• Firewalls & Intrusion Detection: Our infrastructure is protected by multi-layer firewalls and real-time intrusion detection systems monitored continuously.
• Regular Security Audits: ind45 conducts periodic penetration testing and security audits carried out by independent cybersecurity specialists.

10.2 Organizational Safeguards. Access to Personal Data within ind45 is restricted on a strict need-to-know basis. All team members with access to user data are subject to confidentiality obligations and undergo data protection awareness training. Access logs are maintained and reviewed regularly.

10.3 Data Breach Response. In the event of a security breach that poses a risk to your rights and freedoms, ind45 will notify affected users without undue delay, describing the nature of the breach, the data involved, likely consequences, and the measures we have taken or propose to take to address it.

10.4 User Responsibility. While we maintain robust technical and organizational safeguards, the security of your account also depends on you. You must maintain a strong, unique password for your ind45 account, never share your login credentials, and contact us immediately if you suspect unauthorized access to your account.

11 Cookies & Tracking Technologies

11.1 What Are Cookies. Cookies are small text files placed on your device when you visit a website. They allow the website to recognize your device across sessions and store certain preferences or session information.

11.2 Types of Cookies We Use. ind45 uses the following categories of cookies:

• Strictly Necessary Cookies: Essential for the operation of the platform, including maintaining your login session, remembering items in your account, and enabling secure transactions. These cannot be disabled without significantly impairing your ability to use the platform.
• Performance & Analytics Cookies: Help us understand how users interact with ind45 — which pages are visited most often, where users encounter errors, and how long sessions last. This data is aggregated and anonymous.
• Functionality Cookies: Remember your preferences such as language settings, notification preferences, and last-visited game categories to provide a more personalized experience.
• Targeting & Marketing Cookies: Used to deliver promotional content relevant to your interests, both on ind45 and on third-party platforms where we advertise. These are only deployed with your consent.

11.3 Managing Cookies. You can control and manage cookies through your browser settings. Most browsers allow you to refuse new cookies, delete existing cookies, or receive a warning before a cookie is stored. Disabling certain cookies may affect the functionality and performance of the ind45 platform.

11.4 Other Tracking Technologies. In addition to cookies, ind45 may use web beacons, pixel tags, local storage objects, and session replay technologies for security monitoring, fraud detection, and platform analytics. These technologies operate similarly to cookies and are subject to the same user controls where technically feasible.

12 Your Data Rights

ind45 respects your rights over your Personal Data. Depending on applicable law, you may be entitled to exercise the following rights by contacting us at [email protected]:

• Right of Access: You may request a copy of the Personal Data we hold about you, along with information about how it is being processed.
• Right to Rectification: If any Personal Data we hold about you is inaccurate or incomplete, you may request that we correct or update it. For certain account fields, you can update your information directly in 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 (and no other legal basis applies), or where you object to processing and we have no overriding legitimate grounds. Note that certain data must be retained for legal and regulatory compliance purposes and cannot be erased on request.
• Right to Restriction of Processing: You may request that we limit our use of your Personal Data in certain circumstances, such as while a rectification request is being assessed or where you have objected to processing.
• Right to Data Portability: Where processing is based on your consent or contractual necessity, and carried out by automated means, you may request a structured, machine-readable copy of your Personal Data to transfer to another service provider.
• Right to Object: You may object to processing of your Personal Data based on our legitimate interests, or to the use of your data for direct marketing purposes at any time.
• Rights Related to Automated Decision-Making: Where ind45 uses automated processes to make decisions that have a significant effect on you (such as risk-based account restrictions), you have the right to request human review of that decision.

We will respond to all valid rights requests within thirty (30) calendar days of receipt. In complex cases, we may extend this period by a further sixty (60) days, in which case we will notify you of the extension and the reason for it. There is no charge for exercising your rights, unless requests are manifestly unfounded or excessive, in which case we reserve the right to charge a reasonable administrative fee.

13 Protection of Minors

ind45 is strictly an adults-only platform. Access is prohibited to any individual under the age of 21. We do not knowingly collect, use, or store Personal Data from individuals under 21 years of age.

If you believe that a minor has created an account on ind45 or submitted Personal Data to us, please notify us immediately at [email protected]. Upon receiving credible notice, we will promptly investigate and, where confirmed, delete all associated Personal Data and terminate the account without delay.

As part of our commitment to child protection, ind45 supports the use of parental control software to prevent minors from accessing online gambling platforms. We encourage parents and guardians to make use of available tools to restrict access to age-restricted content.

14 Third-Party Services & Links

14.1 Game Providers. Games available on ind45 are supplied by third-party studios including Pragmatic Play, Evolution Gaming, Spribe, Pocket Games Soft, NetEnt, and Microgaming. When you play games provided by these studios, certain technical data (e.g., game session data, RNG seed data) may be processed directly by the game provider's servers. Each provider's own privacy practices govern that processing.

14.2 Payment Partners. Transactions processed via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja are subject to those institutions' own privacy policies and terms of service. ind45 has no control over and accepts no liability for the data practices of third-party financial institutions.

14.3 No External Links. The ind45 platform does not include outbound links to external third-party websites in its main navigation or content areas. Where any reference to an external organization is made (e.g., responsible gambling support resources), you should review that organization's privacy policy independently before submitting any personal information to them.

15 Policy Amendments

ind45 reserves the right to update or amend this Privacy Policy at any time. Changes will be communicated to registered users via email to the registered account address, and a prominent notice will be displayed on the platform, at least fourteen (14) days before material changes take effect. The "Last Updated" date at the top of this document reflects the date of the most recent revision.

We encourage you to review this Policy periodically. Continued use of the ind45 platform following notification of an updated Policy constitutes your acceptance of the revised terms. If you do not agree with any amendment, you must cease using the platform and may close your account by contacting our support team.

Non-material changes (such as typographical corrections, formatting improvements, or clarifications that do not alter the substance of how your data is processed) may be made without advance notice.

16 Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way ind45 handles your Personal Data, please contact us through the following channels:

Email: [email protected]
Live Chat: Available 24/7 directly on the ind45 platform
WhatsApp Support: Available 24/7 (details provided upon login)
Operating Hours: All times in WIB (UTC+7), with coverage also extending to WITA (UTC+8) and WIT (UTC+9) zones

For formal privacy-related notices, please email [email protected] with the subject line "PRIVACY INQUIRY — [Your Concern]". We aim to acknowledge all privacy-related correspondence within twenty-four (24) hours and to resolve matters fully within thirty (30) calendar days.

If you are dissatisfied with our response to a privacy complaint, you retain the right to escalate the matter to the relevant supervisory authority in the jurisdiction governing your rights, or to the data protection authority of our operating license jurisdiction.