ink79 Privacy Policy

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

• "ink79", "we", "us", "our" — refers to the ink79 platform, its operators, and its affiliates responsible for the processing of personal data collected via ink79.app.
• "Platform" — the ink79 website at https://ink79.app, including all pages, subdomains, mobile-optimised views, and any associated applications or services.
• "Player", "you", "your" — any individual who accesses, registers on, or uses the Platform, whether as a registered Account holder or as an unregistered visitor.
• "Account" — a registered player account on the Platform, created following successful completion of the ink79 registration process.
• "Personal Data" — any information that directly or indirectly identifies a natural person, including name, date of birth, email address, mobile number, payment details, device identifiers, and IP addresses.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, and deletion.
• "KYC" — Know Your Customer identity verification procedures required before processing withdrawals or as otherwise required by compliance obligations.
• "IDR" / "Rupiah" — Indonesian Rupiah, the exclusive currency of all financial transactions on the Platform.

ink79 is the data controller responsible for your Personal Data collected through the Platform. As data controller, ink79 determines the purposes and means of processing your Personal Data and is accountable for ensuring that such processing complies with applicable data protection standards and international best practices.

For all privacy-related enquiries, requests, or complaints, the designated point of contact is the ink79 Data Protection team, reachable at [email protected]. The support team is available 24 hours a day, seven days a week, and privacy-related requests are prioritised for response within 72 hours.

ink79 collects the following categories of Personal Data. We collect only what is necessary for the purposes described in this Policy and do not engage in speculative or disproportionate data collection.

ink79 does not collect sensitive personal data categories such as racial or ethnic origin, political opinions, religious beliefs, biometric data for identification purposes (beyond standard KYC photography), or health data, except where a Player voluntarily discloses health-related information in the context of a responsible gaming request.

ink79 collects Personal Data through the following methods:

• Direct Provision: Data you actively provide during Account registration, KYC document submission, deposit and withdrawal requests, support communications, and when participating in surveys or promotions.
• Automated Technologies: When you visit the Platform, our servers automatically log Technical and Usage Data including your IP address, device identifiers, and session behaviour. This is standard practice across all web platforms and is necessary for security monitoring and platform optimisation.
• Payment Processors: When you initiate a deposit or withdrawal via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, or LinkAja, the relevant payment processor shares transaction confirmation data with ink79 for the sole purpose of crediting or debiting your Account.
• KYC Partners: ink79 may use third-party identity verification services to assist with the review of KYC documents. These partners share only the outcome of the verification (verified / not verified) and the minimum data required to complete the check.
• Cookies and Tracking Technologies: As described in Section 8, ink79 uses cookies and similar technologies to maintain session continuity, prevent fraud, and analyse platform usage patterns.

ink79 processes your Personal Data on one or more of the following legal grounds:

• Contractual Necessity: Processing required to create and maintain your Account, process deposits and withdrawals, settle bets, and provide the gaming services you have contracted for. Without this processing, ink79 cannot provide its services.
• Legal Obligation: Processing required to comply with applicable anti-money laundering (AML) standards, KYC obligations, fraud prevention requirements, and the terms of ink79's international gaming licence. This includes mandatory record-keeping of financial transactions.
• Legitimate Interests: Processing necessary for ink79's legitimate business interests, including platform security monitoring, fraud detection, responsible gaming risk assessments, customer support quality improvement, and aggregate analytics. ink79 has assessed that these interests do not override your fundamental privacy rights.
• Consent: Processing for direct marketing communications (promotional emails, SMS offers, seasonal promotions aligned with events such as Idul Fitri, Ramadhan, or Indonesian Independence Day) is based on your freely given, specific, and informed consent at the point of registration or via your Account preferences. You may withdraw this consent at any time.

ink79 uses the Personal Data it collects exclusively for the following purposes:

• Account Management: Creating, maintaining, and securing your ink79 Account; verifying your identity at registration and during KYC; enforcing the 21+ age restriction; and managing Account closures and voluntary self-exclusions.
• Payment Processing: Facilitating IDR deposits and withdrawals via your nominated Indonesian bank account (BCA, BRI, BNI, Mandiri, CIMB Niaga) or e-wallet (OVO, DANA, GoPay, ShopeePay, LinkAja); reconciling transactions; and investigating disputed or failed transactions.
• Gaming Operations: Recording wager history, calculating winnings and losses, applying bonus credits, enforcing wagering requirements, and generating Account statements on request.
• Fraud Prevention & Security: Detecting and preventing fraudulent activity, multiple Account creation, collusion, money laundering, and unauthorised access attempts. Technical and Usage Data are central to these security functions.
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling indicators; enforcing deposit limits, loss limits, and session time restrictions set by the Player; processing cool-off and self-exclusion requests.
• Customer Support: Responding to Account queries, technical issues, payment disputes, bonus enquiries, and responsible gaming requests via live chat and email.
• Legal Compliance: Meeting AML record-keeping obligations, responding to lawful requests from regulatory or law enforcement authorities, and maintaining audit trails required under ink79's international gaming licence.
• Platform Improvement: Aggregated and anonymised usage data is analysed to improve Platform performance, navigation, game selection, and promotional relevance. This analysis does not identify individual players.
• Marketing Communications: Sending promotional emails and SMS messages regarding bonuses, new games, seasonal offers, and VIP programme updates — only to Players who have opted in and have not subsequently withdrawn consent.

ink79 does not sell, rent, or trade your Personal Data to third parties. Data is shared only in the following strictly limited circumstances:

• Payment Processors: Your financial data is shared with the relevant Indonesian bank or e-wallet provider (BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, or LinkAja) solely to the extent necessary to process your deposit or withdrawal. These providers operate under their own privacy policies and are responsible for the security of data within their systems.
• KYC Verification Partners: Identity documents submitted during KYC may be reviewed by a contracted third-party verification service. These partners are bound by strict data processing agreements and may not use your data for any purpose other than the specific verification task.
• Game Technology Providers: Game session data (wager amounts, game round IDs, RNG seeds) is shared with game studios including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Pocket Games Soft, and Spribe solely to the extent required to operate their respective game titles on the Platform. These providers do not receive personally identifiable information beyond what is technically required for the game session.
• Regulatory and Law Enforcement Authorities: ink79 will disclose Personal Data to competent authorities where required by a valid legal order, court order, or regulatory requirement under the framework of ink79's international gaming licence. ink79 will, where legally permissible, notify the affected Player before disclosing their data.
• Business Transfers: In the event of a merger, acquisition, or sale of ink79's business or assets, Personal Data held by ink79 may be transferred to the acquiring entity. Affected Players will be notified prior to the transfer and will retain all rights described in this Policy.
• Fraud Prevention Networks: Where a Player is found to have engaged in fraudulent activity, Account abuse, or money laundering, relevant data may be shared with industry-standard fraud prevention databases to prevent the same individual from defrauding other licensed gaming platforms.

ink79 uses cookies and similar browser-based tracking technologies to support the operation, security, and improvement of the Platform. A cookie is a small text file stored on your device by your web browser when you visit the Platform.

ink79 does not use third-party advertising cookies or allow external ad networks to set cookies on the Platform. You can manage browser-level cookie settings through your browser's privacy or security settings panel; however, disabling strictly necessary cookies will prevent you from logging into your Account.

ink79 retains Personal Data for as long as is necessary to fulfil the purposes described in this Policy, including legal, regulatory, and audit obligations. The following retention periods apply as a general guide:

• Active Account Data: Retained for the full duration of your Account's active status and for a minimum of five years following Account closure, in line with standard AML record-keeping requirements under international gaming compliance frameworks.
• KYC Documents: Retained for a minimum of five years from the date of verification, or from the date of Account closure, whichever is later. This retention is required to satisfy international AML compliance obligations.
• Transaction Records: All deposit, withdrawal, and wager records are retained for a minimum of five years from the date of each transaction. These records are required for audit, dispute resolution, and regulatory review purposes.
• Customer Support Communications: Retained for three years from the date of the last interaction, to support quality assurance reviews and to maintain a record in the event of a later dispute or complaint.
• Marketing Consent Records: Records of your opt-in and opt-out status are retained for five years from the date of the last consent event, to provide evidence of compliance with consent-based marketing obligations.
• Technical and Usage Logs: Anonymised aggregate usage data may be retained indefinitely for platform analytics. Individually identifiable Technical Data (e.g., IP address logs) is retained for 12 months and then purged.

Upon the expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised. Where data cannot be immediately deleted due to backup cycles, it is isolated from active processing systems and scheduled for deletion at the next available cycle.

ink79 maintains a comprehensive set of technical and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, alteration, or disclosure.

• 256-bit SSL/TLS Encryption: All data transmitted between your device and ink79's servers is encrypted using industry-standard 256-bit TLS. This applies to all Platform pages, including the login screen, deposit flow, and KYC document upload portal.
• Password Hashing: Account passwords are never stored in plain text. ink79 uses one-way cryptographic hashing with per-account salting. ink79 staff cannot retrieve your password under any circumstances; if lost, a secure reset process must be followed.
• Access Controls: Access to Personal Data within ink79's internal systems is granted on a strict need-to-know basis. All internal access is logged and audited. Staff with access to Personal Data undergo regular privacy and security training.
• Infrastructure Security: ink79's Platform infrastructure is hosted in secure, access-controlled data centres with physical security, redundant power systems, and 24/7 monitoring. Regular penetration testing is conducted by independent security professionals.
• Fraud Monitoring: ink79 operates real-time fraud monitoring systems that analyse login patterns, device fingerprints, IP geolocation, and transaction behaviour to detect and block suspicious activity before it results in account compromise or financial loss.

As a Player on the ink79 Platform, you have the following rights over your Personal Data. These rights may be exercised at any time by contacting [email protected]. ink79 will respond to all valid rights requests within 30 days of receipt.

• Right of Access: You may request a copy of all Personal Data that ink79 holds about you, together with information about how it is being used and with whom it has been shared.
• Right to Rectification: If any Personal Data held by ink79 is inaccurate or incomplete, you may request that it be corrected or updated. For name or date-of-birth corrections, supporting KYC documentation may be required.
• 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 processing is unlawful. Note that ink79 may be required to retain certain data (e.g., transaction records) to comply with legal and regulatory obligations, even after an erasure request is submitted.
• Right to Restrict Processing: You may request that ink79 restrict the processing of your Personal Data in certain circumstances, such as while a rectification request is being assessed or where you contest the lawfulness of processing.
• Right to Data Portability: For data processed on the basis of your consent or contractual necessity, you may request a machine-readable export of your Personal Data in a structured, commonly used format.
• Right to Object: You may object at any time to processing based on ink79's legitimate interests, including profiling for responsible gaming purposes. You may also withdraw consent for direct marketing at any time; your Account's marketing preferences can be updated immediately via Account settings or by contacting support.

ink79 is strictly a 21+ platform. The collection of Personal Data from individuals under 21 years of age is expressly prohibited. ink79 employs age verification controls at the point of registration and during KYC to prevent access by minors.

If ink79 determines or is notified that Personal Data belonging to a person under 21 years of age has been collected, ink79 will immediately suspend the Account, delete all associated Personal Data that is not required to be retained for legal or regulatory compliance purposes, and return any deposited funds to the originating payment method. Parents and guardians who believe that a minor has registered on the Platform should contact [email protected] immediately with supporting details.

ink79 recommends that parents and guardians install device-level parental control software to restrict access to gambling platforms, including ink79.app, by minors in their household. Widely used parental control tools are available for Windows, macOS, iOS, and Android devices.

The ink79 Platform integrates with a number of third-party technology and service providers to deliver its core functionality. These include game studios (Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Pocket Games Soft, Spribe), payment processors, and identity verification services. Each of these providers operates under its own privacy policy and data protection standards.

ink79 conducts due diligence on all third-party providers before integration and requires that each provider maintains data security standards consistent with or exceeding those described in this Policy. ink79 is not responsible for the privacy practices of external platforms or websites that are not operated by ink79, including the websites of payment providers such as BCA, BRI, BNI, Mandiri, OVO, or DANA.

The Platform does not contain links to third-party websites for advertising or affiliate purposes. All navigation links on ink79.app point exclusively to ink79-operated pages.

As an internationally licensed and operated platform serving Indonesian players, ink79 may process and store Personal Data on servers located outside Indonesia. Where Personal Data is transferred internationally, ink79 implements appropriate safeguards to ensure that your data receives a level of protection consistent with the standards described in this Policy.

Applicable safeguards include: contractual data processing agreements with all recipients that mandate equivalent data protection standards; transfer only to jurisdictions with adequate data protection frameworks as assessed by ink79's compliance team; and technical measures including encryption in transit and at rest to protect data regardless of its location.

By registering for an ink79 Account and accepting these terms, you acknowledge and consent to the international transfer of your Personal Data as described in this section.

ink79 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, platform functionality, or data processing practices. When material changes are made, ink79 will notify registered Players via their registered email address and/or by displaying a prominent update notice on the Platform at least 7 days before the revised Policy takes effect.

The "Last updated" date at the top of this document will be revised each time the Policy is updated. We encourage you to review this Policy periodically. 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 agree with any change, you should cease using the Platform and contact [email protected] to request Account closure and the return of any verified real-money balance.

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your Personal Data by ink79, please contact us using the details below:

If you are not satisfied with ink79's response to your privacy concern, you have the right to escalate your complaint to the relevant regulatory or supervisory authority under the framework of ink79's international gaming licence.