Privacy Policy

1. Introduction and Scope

This Privacy Policy governs the collection, use, disclosure, and protection of personal information by nemo99 ("we," "us," or "our") from users ("you" or "your") of our online betting and gaming platform, including our website, mobile applications, and all related services. This policy applies to all personal data processed by nemo99, whether collected directly from you or obtained from third-party sources.

nemo99 operates as an international online gambling platform serving primarily Indonesian players. We process personal data in accordance with international data protection standards, including principles derived from the General Data Protection Regulation (GDPR) and other applicable privacy frameworks. While Indonesia does not currently have comprehensive data protection legislation equivalent to GDPR, we voluntarily apply these high standards to protect all our users regardless of their jurisdiction.

By creating an account with nemo99, depositing funds, placing bets, or otherwise using our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.

2. Data Controller Information

nemo99 acts as the data controller for all personal information collected through our platform. We determine the purposes and means of processing your personal data. For questions, concerns, or requests regarding your personal information or this Privacy Policy, you may contact our Data Protection Officer through the following channels:

• Email: [email protected] or [email protected] (marked "Attention: Data Protection Officer")
• Live Chat: Available 24/7 through our website (request to speak with Data Protection team)
• Response Time: We aim to respond to all privacy inquiries within 72 hours

3. Information We Collect

3.1 Personal Information You Provide

When you register for a nemo99 account or use our services, we collect the following categories of personal information directly from you:

• Registration Information: Full legal name (as it appears on government-issued identification), date of birth, gender, email address, phone number, residential address (street address, city, province, postal code), username, and password.
• Identity Verification Documents: Government-issued identification such as Indonesian ID card (Kartu Tanda Penduduk or KTP), passport, or driver's license. These documents may include your photograph, ID number, issue and expiry dates, and other information appearing on the document.
• Financial Information: Bank account details (bank name, account number, account holder name) for Indonesian banks including BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, and Bank Permata; e-wallet account information for OVO, DANA, GoPay, ShopeePay, and LinkAja; transaction history including deposits, withdrawals, and payment method details.
• Communication Records: Correspondence with our customer support team via live chat, email, WhatsApp, or in-app messaging, including the content of your messages, attachments, and support ticket records.
• Optional Information: Marketing preferences, language preferences, promotional code usage, survey responses, and feedback provided voluntarily by you.

3.2 Information Automatically Collected

When you access and use nemo99, we automatically collect certain technical and usage information through cookies, web beacons, and similar technologies:

• Device Information: Device type (desktop, tablet, smartphone), operating system and version (Windows, macOS, iOS, Android), browser type and version, screen resolution, device identifiers (IMEI, UDID), and mobile network information.
• Connection Information: IP address, internet service provider (ISP), connection speed, geographic location (derived from IP address at the city and country level), and timezone.
• Usage Data: Pages visited, features accessed, time spent on each page, clickstream data, search queries, bet history (sports events wagered on, bet types, stake amounts, odds, outcomes), game play records (games played, session duration, bet amounts, winnings/losses), bonus usage, and navigation patterns.
• Technical Logs: Server logs, error reports, performance data, and diagnostic information used to maintain and improve platform stability and security.

3.3 Information from Third Parties

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

• Payment Processors: Transaction verification data from Indonesian banks and e-wallet providers to confirm deposits and process withdrawals.
• Identity Verification Services: Results of identity checks and fraud screening from third-party KYC and AML compliance providers.
• Affiliate Partners: Referral source information if you accessed nemo99 through an affiliate link or marketing partner.
• Publicly Available Sources: Information from public databases or registries used to verify identity or comply with legal obligations.

4. How We Use Your Information

nemo99 processes your personal information for the following purposes, based on various legal grounds including contractual necessity, legal obligations, legitimate interests, and your consent:

4.1 Account Management and Service Delivery

• Create and maintain your nemo99 account
• Verify your identity and age (21+ requirement) in compliance with responsible gaming standards
• Process deposits and withdrawals to and from your account
• Enable you to place bets on sports events, play casino games, participate in togel lottery draws, and use all platform features
• Record and settle your bets, calculate winnings, and credit payouts to your account
• Provide customer support and respond to your inquiries
• Send transactional communications such as account notifications, deposit confirmations, withdrawal status updates, and security alerts

4.2 Security, Fraud Prevention, and Legal Compliance

• Detect, prevent, and investigate fraudulent activity, money laundering, bonus abuse, collusion, and other violations of our Terms & Conditions
• Monitor account activity for suspicious patterns that may indicate problem gambling or account compromise
• Comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations required by our licensing jurisdiction
• Enforce our Terms & Conditions and other policies
• Respond to legal requests, court orders, and regulatory inquiries from competent authorities
• Protect the rights, property, and safety of nemo99, our users, and the public

4.3 Platform Improvement and Analytics

• Analyze user behavior and preferences to improve our website, mobile apps, and services
• Conduct A/B testing to optimize user experience and interface design
• Develop new features, games, and betting markets based on user demand
• Generate aggregated, anonymized statistics and reports for internal business purposes
• Monitor platform performance, identify technical issues, and maintain system stability

4.4 Marketing and Communications

With your explicit consent, we may use your information to:

• Send promotional emails about bonuses, special offers, new games, and platform updates
• Display personalized content, offers, and recommendations based on your gaming preferences and history
• Contact you via SMS, WhatsApp, or push notifications about promotions (you can opt out at any time)
• Conduct surveys and request feedback to improve our services
• Provide VIP members with exclusive offers and personalized account management services

You can withdraw your consent for marketing communications at any time by clicking "unsubscribe" in any promotional email, adjusting your account communication preferences, or contacting customer support. Opting out of marketing will not affect transactional communications necessary for service delivery.

5. Legal Basis for Processing (GDPR Framework)

Although nemo99 primarily serves Indonesian users and Indonesian law does not currently require explicit legal bases for data processing, we voluntarily align with GDPR principles. We process your personal data based on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contract with you (providing betting and gaming services, processing transactions, managing your account).
• Legal Obligation: Processing is required to comply with legal obligations, including KYC/AML regulations, age verification requirements, and responses to lawful requests from authorities.
• Legitimate Interests: Processing is necessary for our legitimate business interests, including fraud prevention, security monitoring, platform improvement, and analytics, provided these interests do not override your fundamental rights.
• Consent: You have given explicit consent for specific processing activities, particularly marketing communications and personalized content. Consent can be withdrawn at any time.

6. How We Share Your Information

nemo99 does not sell your personal information to third parties. We share your information only in the limited circumstances described below, and we require all recipients to maintain appropriate security measures and use the information only for specified purposes.

6.1 Service Providers and Business Partners

We share personal information with trusted third-party service providers who perform functions on our behalf, including:

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay) to process deposits and withdrawals. They receive only the information necessary to complete transactions (name, account number, transaction amount).
• Identity Verification Services: Third-party KYC/AML compliance providers that verify your identity, age, and screen against sanctions lists and politically exposed persons (PEP) databases.
• Gaming Software Providers: Companies like Pragmatic Play, Evolution Gaming, Microgaming, and NetEnt receive minimal data (typically just a user ID) necessary to enable game play and record results.
• Customer Support Tools: Live chat platforms and customer relationship management (CRM) systems used to deliver support services.
• Cloud Infrastructure Providers: Hosting services, database management, and backup services that store and process data on our behalf.
• Marketing and Analytics Platforms: Tools used for email marketing, push notifications, and website analytics (with your consent for marketing purposes).

All service providers operate under strict contractual obligations to maintain confidentiality, implement appropriate security measures, process data only as instructed by nemo99, and delete or return data upon termination of services.

6.2 Legal and Regulatory Disclosures

We may disclose your personal information when required by law or when we believe disclosure is necessary to:

• Comply with court orders, subpoenas, or other legal processes
• Respond to lawful requests from regulatory authorities or law enforcement agencies
• Meet tax reporting or financial audit requirements
• Cooperate with investigations into fraud, money laundering, or other illegal activities
• Protect the rights, property, and safety of nemo99, our users, or the public

6.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy involving nemo99, your personal information may be transferred to the acquiring entity or successor company. You will be notified of any such change via email and/or prominent notice on our website, and you will have the opportunity to close your account and request data deletion before the transfer if you do not consent to the new owner processing your information.

7. International Data Transfers

nemo99 operates from servers located outside Indonesia. By using our services, you understand and consent to the transfer of your personal information to jurisdictions that may not provide the same level of data protection as Indonesian law (if and when comprehensive Indonesian data protection legislation is enacted) or the GDPR framework.

When we transfer personal data internationally, we implement appropriate safeguards, including:

• Contractual clauses requiring recipients to protect data according to international standards
• Encryption of data in transit and at rest
• Limiting data transfers to jurisdictions with adequate data protection frameworks
• Conducting privacy impact assessments for high-risk transfers

8. Data Security Measures

nemo99 implements industry-standard technical and organizational security measures to protect your personal information against unauthorized access, loss, misuse, alteration, or destruction:

• Encryption: All data transmitted between your device and our servers is encrypted using SSL/TLS protocols (minimum 256-bit encryption). Sensitive data stored in our databases is encrypted at rest.
• Access Controls: Personal data is accessible only to authorized nemo99 employees and contractors who require access to perform their job functions. Access is logged and monitored.
• Authentication: Two-factor authentication (2FA) is available for user accounts and mandatory for all staff with access to user data.
• Regular Audits: We conduct regular security audits, vulnerability assessments, and penetration testing to identify and remediate potential weaknesses.
• Employee Training: All staff receive mandatory training on data protection principles, security best practices, and incident response procedures.
• Incident Response Plan: We maintain a documented data breach response plan to ensure rapid detection, containment, and notification in the unlikely event of a security incident.

Despite our best efforts, no security system is impenetrable. If we become aware of a data breach that compromises your personal information, we will notify you without undue delay (typically within 72 hours of discovery) and provide information about the nature of the breach, the data affected, and steps you should take to protect yourself.

9. Data Retention

nemo99 retains 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 vary based on data type and legal requirements:

• Active Accounts: Personal information associated with active accounts is retained for the duration of your relationship with nemo99 and for a reasonable period thereafter to handle any disputes or investigations.
• Closed Accounts: After you close your account, we retain certain information for up to seven (7) years to comply with financial regulations, tax laws, and AML requirements. This includes identity verification documents, transaction records, and bet history.
• Marketing Data: If you opt out of marketing communications, we retain your email address in a suppression list to ensure we do not contact you again, but we delete other marketing-related data.
• Support Records: Customer support communications are typically retained for two (2) years for quality assurance and dispute resolution purposes.
• Legal Holds: If information is subject to a legal hold (e.g., pending litigation or regulatory investigation), we retain it until the hold is lifted, regardless of standard retention periods.

After retention periods expire, personal data is securely deleted or anonymized so that it can no longer be associated with you.

10. Your Privacy Rights

Subject to applicable law and certain exceptions, you have the following rights regarding your personal information:

• Right of Access: You can request confirmation of whether we process your personal data and obtain a copy of that data. You may submit access requests through your account settings or by contacting our Data Protection Officer.
• Right to Rectification: If your personal information is inaccurate or incomplete, you can request that we correct or update it. Most information can be edited directly in your account settings.
• Right to Erasure ("Right to be Forgotten"): You can request deletion of your personal data, subject to our legal obligations to retain certain information for regulatory compliance, financial record-keeping, and fraud prevention.
• Right to Restriction of Processing: You can request that we limit how we process your personal data in certain circumstances, such as while we investigate the accuracy of data you have disputed.
• Right to Data Portability: You can request a copy of your personal data in a structured, commonly used, machine-readable format that can be transferred to another service provider.
• Right to Object: You can object to processing based on legitimate interests or for direct marketing purposes. We will cease processing unless we have compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on consent (e.g., marketing communications), you can withdraw that consent at any time without affecting the lawfulness of processing conducted before withdrawal.

To exercise any of these rights, contact our Data Protection Officer via email at [email protected] or through live chat. We will respond to your request within 30 days and may request additional information to verify your identity before processing the request.

11. Cookies and Tracking Technologies

nemo99 uses cookies and similar technologies to enhance user experience, analyze site usage, and deliver personalized content. Cookies are small text files stored on your device that allow us to recognize you on subsequent visits. We use the following types of cookies:

• Essential Cookies: Necessary for the operation of our platform, including session management, load balancing, and security features. These cannot be disabled without affecting site functionality.
• Functional Cookies: Remember your preferences (language, timezone, display settings) to provide a more personalized experience.
• Analytics Cookies: Collect anonymized information about how visitors use our site, helping us improve navigation and content.
• Marketing Cookies: Track your activity across websites to deliver targeted advertising and measure campaign effectiveness (used only with your consent).

You can manage cookie preferences through your browser settings. Note that disabling essential cookies may limit platform functionality. For more information, see our Cookie Policy.

12. Third-Party Links

Our website may contain links to third-party websites, including payment processors, social media platforms, and partner sites. nemo99 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 sites you visit.

13. Children's Privacy

nemo99 services are strictly intended for individuals aged 21 and above. We do not knowingly collect personal information from anyone under 21. If we become aware that we have inadvertently collected information from a minor, we will immediately delete that information and close the associated account. Parents or guardians who believe their child has provided personal information to nemo99 should contact us immediately.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service offerings. The "Last Updated" date at the top of this policy indicates when it was most recently revised. Material changes will be communicated via email and/or prominent notice on our website at least 30 days before taking effect. Your continued use of nemo99 after the effective date constitutes acceptance of the updated policy.

15. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact our Data Protection Officer:

• Email: [email protected] or [email protected]
• Live Chat: Available 24/7 (request Data Protection team)
• Response Time: We aim to respond within 72 hours

If you are not satisfied with our response, you have the right to lodge a complaint with the data protection authority in your jurisdiction, if applicable.