Privacy Policy

1. Introduction

This Privacy Policy applies to all users of the cuan23 website, mobile applications, and related services (collectively, the "Platform"). It describes how cuan23 ("We," "Us," "Our," or the "Company") collects, processes, stores, and shares your personal information in accordance with applicable Indonesian data protection laws and regulations.

We recognize that privacy is a fundamental right, and we are committed to handling your data with transparency, fairness, and security. This policy is designed to help you understand:

• What personal data we collect and why
• How we use and protect your information
• Your rights regarding your personal data
• How to contact us with privacy-related questions or concerns

2. Information We Collect

2.1 Personal Information You Provide

When you register an account with cuan23, you voluntarily provide us with certain personal information, including but not limited to:

• Identity Information: Full legal name, date of birth, gender, nationality, and copies of government-issued identification documents (e.g., Indonesian national ID / KTP)
• Contact Information: Email address, mobile phone number, and residential address
• Account Credentials: Username, password, and security questions
• Financial Information: Bank account details, e-wallet account information, payment card details, and transaction history
• Verification Documents: Selfies, proof of address documents, and bank statements submitted during the KYC (Know Your Customer) process

2.2 Information Collected Automatically

When you access and use the cuan23 Platform, we automatically collect certain technical and usage data, including:

• Device Information: IP address, browser type and version, operating system, device identifiers (IMEI, MAC address), screen resolution, and language settings
• Usage Data: Pages visited, features accessed, time spent on the Platform, clickstream data, referring and exit pages, search queries, and interaction with advertisements
• Location Data: Approximate geographic location derived from your IP address (we do not collect precise GPS location unless you explicitly grant permission)
• Cookies and Tracking Technologies: We use cookies, web beacons, pixel tags, and similar technologies to recognize returning users, personalize your experience, and analyze site traffic (see Section 8 for details)

2.3 Information from Third Parties

We may receive information about you from third-party sources, including:

• Payment Processors: Transaction data from banks, e-wallet providers, and payment gateways (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay)
• Identity Verification Services: Results from third-party KYC and anti-fraud screening services
• Marketing Partners: Aggregated demographic and interest data from advertising networks (this data is anonymized and does not identify you personally)

3. How We Use Your Information

cuan23 uses your personal information for the following purposes:

3.1 Account Management and Service Delivery

• Create and maintain your player account
• Process deposits, withdrawals, and refunds
• Verify your identity and prevent underage gambling
• Provide customer support and respond to your inquiries
• Administer bonuses, promotions, and loyalty rewards
• Send transactional notifications (account confirmations, withdrawal approvals, password resets)

3.2 Legal and Regulatory Compliance

• Comply with Indonesian anti-money laundering (AML) and counter-terrorism financing (CTF) regulations
• Fulfill KYC and customer due diligence obligations
• Detect and prevent fraud, cheating, collusion, and other prohibited activities
• Cooperate with law enforcement and regulatory authorities when legally required
• Enforce our Terms and Conditions and protect the integrity of our Platform

3.3 Marketing and Communications

• Send promotional emails, SMS messages, and push notifications about new games, bonuses, and special offers (you may opt out at any time)
• Personalize marketing content based on your betting preferences and activity history
• Conduct surveys and request feedback to improve our services

3.4 Analytics and Platform Improvement

• Analyze user behavior to optimize site performance, navigation, and user experience
• Identify technical issues and troubleshoot platform errors
• Conduct A/B testing of new features and design elements
• Generate anonymized, aggregated statistics for business intelligence purposes

4. Legal Basis for Processing (Indonesia)

Under Indonesian data protection principles, we process your personal information based on the following legal grounds:

• Contractual Necessity: Processing is necessary to fulfill our obligations under the Terms and Conditions you accepted when creating your account
• Legal Obligation: Processing is required to comply with Indonesian laws and regulations, including AML/CTF and KYC requirements
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security monitoring, and service improvement, provided these interests do not override your privacy rights
• Consent: For marketing communications and non-essential cookies, we obtain your explicit consent, which you may withdraw at any time

5. How We Share Your Information

cuan23 does not sell or rent your personal information to third parties. However, we may share your data with the following categories of recipients:

5.1 Service Providers and Business Partners

Recipient Type	Purpose	Examples
Payment Processors	Process deposits and withdrawals	BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay
KYC Verification Services	Verify identity and prevent fraud	Third-party identity verification providers
Game Providers	Deliver casino games and betting markets	Pragmatic Play, Evolution Gaming, NetEnt
Cloud Hosting Providers	Store data and host Platform infrastructure	AWS, Google Cloud, Microsoft Azure
Customer Support Tools	Manage live chat and support tickets	Zendesk, Intercom, LiveChat
Analytics Providers	Analyze site traffic and user behavior	Google Analytics, Mixpanel

All third-party service providers are contractually obligated to protect your data and use it only for the purposes we specify.

5.2 Legal and Regulatory Authorities

We may disclose your information to government agencies, law enforcement, or regulatory bodies if required by law, court order, or legal process, or if we believe disclosure is necessary to:

• Comply with legal obligations
• Protect the rights, property, or safety of cuan23, our users, or the public
• Detect, prevent, or investigate fraud, security breaches, or illegal activity

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets, your personal information may be transferred to the acquiring entity. We will notify you of any such change and provide you with choices regarding your data.

6. Data Security

cuan23 employs industry-standard security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. Our security practices include:

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS protocols
• Secure Storage: Personal data is stored on secure servers with restricted access, firewall protection, and regular security audits
• Access Controls: Only authorized personnel with a legitimate business need can access your personal information
• Two-Factor Authentication: We offer 2FA to add an extra layer of protection to your account
• Regular Monitoring: We continuously monitor our systems for suspicious activity and potential security threats

While we implement robust security measures, no method of transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and notifying us immediately if you suspect unauthorized access.

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Specific retention periods include:

• Active Accounts: Personal data is retained for the duration of your account's active status
• Closed Accounts: After account closure, we retain certain information for up to 7 years to comply with Indonesian financial record-keeping and AML regulations
• Marketing Data: If you opt out of marketing communications, we will retain a record of your opt-out preference indefinitely to honor your request
• Transaction Records: Financial transaction data is retained for 7 years as required by Indonesian tax and banking laws

After the applicable retention period expires, we will securely delete or anonymize your personal information.

8. Cookies and Tracking Technologies

8.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help the site recognize your device on return visits and remember your preferences.

8.2 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function (e.g., session authentication, security features). You cannot opt out of these cookies.
• Performance Cookies: Collect anonymous data on how users interact with the site (e.g., page views, load times). Used to improve site performance.
• Functionality Cookies: Remember your preferences (e.g., language, currency, username). Enhance user experience.
• Advertising Cookies: Track your activity across websites to deliver personalized ads. Placed by third-party advertising networks.

8.3 Managing Cookies

You can control cookie settings through your browser. Most browsers allow you to block or delete cookies. However, disabling essential cookies may prevent you from accessing certain features of the Platform.

9. Your Privacy Rights

Under Indonesian data protection principles, you have the following rights regarding your personal information:

• Right to Access: Request a copy of the personal data we hold about you
• Right to Rectification: Correct inaccurate or incomplete information
• Right to Erasure: Request deletion of your data (subject to legal retention requirements)
• Right to Restrict Processing: Request that we limit how we use your data
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Opt out of marketing communications and certain types of data processing
• Right to Withdraw Consent: Withdraw consent for processing activities that require it (does not affect the lawfulness of processing before withdrawal)

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days.

10. Children's Privacy

cuan23 services are strictly prohibited for individuals under the age of 21 years. We do not knowingly collect personal information from minors. If we discover that we have inadvertently collected data from someone under 21, we will immediately delete that information and close the associated account. If you believe a minor has provided us with personal information, please contact us immediately.

11. International Data Transfers

Your personal information may be transferred to and processed in countries outside Indonesia, including countries that may not have the same level of data protection as Indonesia. When we transfer data internationally, we ensure that appropriate safeguards are in place, such as:

• Contractual clauses requiring recipients to protect your data
• Certification under recognized data protection frameworks
• Encryption and secure transmission protocols

12. Third-Party Links

Our Platform may contain links to third-party websites, services, or advertisements. cuan23 is not responsible for the privacy practices or content of these external sites. We encourage you to review the privacy policies of any third-party site you visit.

13. Changes to This Privacy Policy

cuan23 reserves the right to update or modify this Privacy Policy at any time. Any changes will be effective immediately upon posting to the Platform. We will notify you of material changes via email or prominent notice on the site. Your continued use of the Platform after such changes constitutes your acceptance of the revised Privacy Policy.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Email: [email protected]
• Live Chat: Available 24/7 on the Platform
• Mailing Address: cuan23 Data Protection Officer, Indonesia (available upon request)