Privacy Policy

1. Definitions

For the purposes of this Privacy Policy, the following terms carry the meanings assigned below:

• "33zkh5," "we," "us," or "our" — the operator of the platform at https://33zkh5.cam and all associated services.
• "User," "you," or "your" — any individual who accesses, registers for, or uses the 33zkh5 platform.
• "Personal Data" — any information that identifies or can be used to identify a natural person, including name, email address, phone number, date of birth, bank account details, and device identifiers.
• "Processing" — any operation performed on personal data, including collection, storage, use, disclosure, or deletion.
• "Data Controller" — 33zkh5, the entity that determines the purposes and means of processing personal data.
• "Third Party" — any person or organization other than the User and 33zkh5, including payment processors, game providers, identity verification services, and analytics vendors.
• "Cookie" — a small text file stored on your device by a web browser for the purpose of tracking session activity, preferences, and behavior on the platform.

2. Data We Collect

33zkh5 collects only the personal data that is necessary to provide our services, comply with legal obligations, and protect the security of the platform and its users. The categories of personal data we collect include:

2.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identification document
• Date of birth (to verify that you meet the 21+ age requirement)
• Indonesian national identification number (KTP number) where required for KYC purposes
• Residential address, city, and province within Indonesia
• Email address
• Mobile phone number (Indonesian number format)

2.2 Financial and Payment Data

• Bank account details, including account holder name, bank name (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, or Bank Permata), and account number
• E-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja account numbers or registered phone numbers)
• Transaction history, including deposit amounts, withdrawal requests, and timestamps
• Wagering history, including bets placed, games played, outcomes, and account balance changes

2.3 Verification and KYC Data

• Copies of government-issued photo identification (KTP, passport, or SIM)
• Proof of address documents (utility bills, bank statements)
• Selfie photographs taken during the identity verification process
• KYC verification status and associated audit records

2.4 Technical and Device Data

• IP address and approximate geolocation (city/province level)
• Device type, operating system version, and browser type
• Session login timestamps, duration, and activity logs
• Platform feature usage patterns (pages visited, games accessed, features used)
• Cookie identifiers and session tokens

2.5 Communications Data

• Records of live chat conversations with our customer support team
• Email correspondence sent to or received from [email protected]
• Records of any complaint, dispute, or feedback submitted through the platform

3. How We Collect Your Data

33zkh5 collects your personal data through the following methods:

• Direct collection: Information you provide voluntarily when registering an account, completing KYC verification, making deposits or withdrawal requests, or contacting customer support.
• Automated collection: Technical data collected automatically when you access the platform, including IP address, device identifiers, cookies, and session activity logs.
• Third-party verification: Identity and document verification data collected via our KYC service providers when you submit identification documents for account verification.
• Payment processing: Transaction data received from payment processors and Indonesian banks and e-wallets (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, LinkAja) when you initiate deposit or withdrawal transactions.
• Game providers: Aggregated gameplay and wagering data received from our game provider partners (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, Pocket Games Soft) to facilitate bet settlement and maintain game integrity.

4. Purpose of Processing

We process your personal data only for specific, documented, and legitimate purposes. The table below summarizes the primary purposes for which 33zkh5 processes personal data:

Purpose	Data Categories Used
Account registration and management	Identity, contact, device data
Age verification (21+ requirement)	Date of birth, KTP / passport data
KYC identity verification	Identity, verification documents, selfie
Processing deposits and withdrawals in IDR	Financial, payment, transaction data
Fraud prevention and security monitoring	All categories including device and IP data
Regulatory compliance and anti-money-laundering (AML)	Identity, financial, transaction data
Customer support and dispute resolution	Communications, account, transaction data
Responsible gaming monitoring and intervention	Wagering history, session activity, self-exclusion records
Platform performance and personalization	Device, session, usage data
Marketing communications (with consent)	Contact data, preferences, wagering interests

5. Legal Basis for Processing

33zkh5 processes personal data on one or more of the following legal bases, in line with internationally recognized data protection principles:

• Contractual necessity: Processing required to fulfill the service agreement between you and 33zkh5, including account management, payment processing, and bet settlement.
• Legal obligation: Processing required to comply with applicable legal obligations, including KYC verification, anti-money-laundering (AML) reporting, and age verification requirements.
• Legitimate interests: Processing necessary for the legitimate interests of 33zkh5 or third parties, including fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your fundamental rights.
• Consent: Processing based on your explicit, freely given, and informed consent — specifically for marketing communications and optional platform personalization features. You may withdraw consent at any time by contacting customer support.

6. Sharing Your Personal Data

33zkh5 does not sell your personal data to any third party. We share personal data only with trusted partners and service providers under strict contractual data protection obligations, and only where necessary for the purposes described in this policy.

6.1 Categories of Recipients

• Payment processors and financial institutions: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) receive transaction data necessary to process your deposits and withdrawals.
• KYC and identity verification providers: Certified third-party identity verification services receive your identification documents and biometric data solely for the purpose of verifying your identity and age.
• Game providers: Licensed game studios (including Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Pocket Games Soft) receive anonymized session and wagering data necessary for game operation and settlement.
• Fraud prevention and security services: Specialized third-party security providers may access device, IP, and behavioral data to detect and prevent unauthorized access, fraud, and bonus abuse.
• Customer support platform providers: Live chat and ticketing system providers that power our 24/7 Indonesian-speaking support team receive communications data necessary to process your support requests.
• Regulatory authorities: We may be required by law to disclose personal data to law enforcement authorities, regulatory bodies, or courts in response to valid legal requests or to comply with reporting obligations.

6.2 No Third-Party Marketing

We will never share your personal data with third-party advertisers, marketing agencies, or data brokers for their own marketing purposes. Any marketing communications you receive will come directly from 33zkh5 and only if you have given us explicit consent to send them.

7. International Data Transfers

As an internationally operated platform, 33zkh5 may transfer your personal data to servers, processors, or service providers located outside Indonesia. Where such transfers occur, we ensure that appropriate safeguards are in place to protect your data, including:

• Contractual clauses requiring recipient organizations to apply data protection standards equivalent to those described in this policy
• Working exclusively with service providers who maintain internationally recognized security certifications (including ISO 27001 or SOC 2 Type II compliance)
• Limiting international transfers to the minimum data necessary for the specific processing purpose

All data transfers are conducted over encrypted connections (TLS 1.2 or higher) to prevent interception during transmission.

8. Data Retention

33zkh5 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws and regulations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of 5 years following account closure, as required for anti-money-laundering compliance.
• KYC documents: Retained for a minimum of 5 years from the date of verification or account closure, whichever is later, in accordance with international AML regulatory requirements.
• Transaction and wagering records: Retained for a minimum of 5 years from the date of each transaction for financial audit and compliance purposes.
• Customer support communications: Retained for 2 years from the date of the last interaction, or longer if required for ongoing dispute resolution.
• Marketing consent records: Retained for the duration of your account or until you withdraw consent, plus 1 year for compliance documentation purposes.
• Device and session logs: Retained for 12 months from the date of collection for security and fraud prevention purposes.

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

9. Data Security

33zkh5 implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. Our security framework includes:

• 256-bit SSL/TLS encryption applied to all data transmitted between your device and our servers, ensuring that your login credentials, payment details, and personal information cannot be intercepted in transit.
• Encrypted data storage for all sensitive personal data, including payment details and KYC documents, using AES-256 encryption at rest.
• Access controls and role-based permissions restricting access to personal data to only those employees and service providers who require it to perform their specific duties.
• Multi-factor authentication (MFA) available for user accounts and mandatory for all administrative access to systems containing personal data.
• Regular third-party security audits and penetration testing conducted by independent cybersecurity firms to identify and remediate vulnerabilities before they can be exploited.
• 24/7 intrusion detection and monitoring with automated alerting systems that flag unusual access patterns, potential account takeovers, or suspicious transaction behavior in real time.
• Data breach response protocol — in the event of a confirmed personal data breach that poses a risk to your rights and freedoms, 33zkh5 will notify affected users promptly and take all necessary remedial action.

While we take every reasonable precaution to protect your data, no system is entirely immune to security risks. You are equally responsible for maintaining the security of your account by keeping your password confidential and not sharing your login credentials with any third party.

10. Cookies & Tracking Technologies

10.1 What Are Cookies?

Cookies are small text files that are placed on your device when you visit the 33zkh5 platform. They allow the platform to recognize your device, maintain your session, remember your preferences, and analyze how you interact with our services.

10.2 Types of Cookies We Use

• Strictly necessary cookies: These cookies are essential for the platform to function. They maintain your login session, remember your account preferences, and enable core security features. These cookies cannot be disabled without impairing the functionality of the platform.
• Performance and analytics cookies: These cookies collect anonymized information about how users interact with the platform — which pages are visited most frequently, how long sessions last, and where users encounter technical issues. This data helps us continuously improve the platform experience.
• Functional cookies: These cookies remember your preferences, such as your preferred language, currency display settings, and game category selections, to personalize your experience on return visits.
• Fraud prevention cookies: These cookies form part of our security infrastructure by tracking device fingerprints and behavioral patterns to detect and prevent unauthorized access, account takeovers, and fraudulent activity.

10.3 Managing Cookies

You can control non-essential cookies through your browser settings. Most modern browsers allow you to view, block, or delete cookies at any time. Please note that disabling cookies may affect the functionality of the 33zkh5 platform, including your ability to stay logged in or access certain features. Strictly necessary and fraud prevention cookies cannot be disabled without impairing platform access.

11. Your Data Rights

As a user of the 33zkh5 platform, you hold the following rights over your personal data. To exercise any of these rights, please contact our Data Protection team at [email protected]. We will respond to all verified requests within 30 days.

• Right of Access: You have the right to request a copy of all personal data that 33zkh5 holds about you, including the categories of data collected, the purposes for which it is processed, and the third parties with whom it has been shared.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it promptly.
• Right to Erasure ("Right to be Forgotten"): You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations (particularly AML and KYC record-keeping requirements).
• Right to Restriction of Processing: You may request that we temporarily restrict the processing of your personal data while we verify its accuracy or consider an objection you have raised.
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, machine-readable format for transfer to another service provider.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, though such objections will be balanced against our operational needs and legal obligations.
• Right to Withdraw Consent: Where processing is based on your explicit consent (for example, marketing communications), you may withdraw that consent at any time by contacting our customer support team. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

12. Minors and Age Restriction

The 33zkh5 platform is strictly intended for adults aged 21 years and above. We do not knowingly collect, store, or process personal data belonging to any person under the age of 21. All registration attempts are subject to age verification, and we require documentary proof of age as part of our KYC procedures.

If we become aware that personal data has been collected from an individual under the age of 21, we will immediately suspend the associated account, delete all collected personal data, and reverse any financial transactions associated with the underage account. If you believe that a minor may have registered an account on 33zkh5, please contact us immediately at [email protected].

13. Changes to This Privacy Policy

33zkh5 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will notify active users via the email address registered to their account or through a prominent notice on the platform before the changes take effect.

The "Last Updated" date at the top of this policy reflects the most recent revision. We encourage you to review this Privacy Policy periodically to remain informed about how we protect your personal data. Continued use of the 33zkh5 platform following notification of changes constitutes your acceptance of the revised policy.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way 33zkh5 handles your personal data, please contact our Data Protection team using the details below:

• Email: [email protected]
• Live Chat: Available 24/7 through the platform — Indonesian-speaking agents are available around the clock
• Response Time: We aim to acknowledge all data-related inquiries within 24 hours and to provide a full response within 30 days of receiving a verified request
• Coverage: Support available across all Indonesian time zones — WIB (UTC+7), WITA (UTC+8), and WIT (UTC+9)