PRIVACY POLICY

1. Introduction

This Privacy Policy applies to all users of the gm108 platform, including visitors to our website, registered members, and anyone who interacts with our services. gm108 operates as an online gaming and entertainment platform serving the Indonesian market, and we process personal data in accordance with applicable data protection laws and regulations.

This policy should be read in conjunction with our Terms and Conditions, which govern your use of the gm108 platform. If you have any questions about how we handle your personal data, please contact our Data Protection Officer using the contact information provided at the end of this policy.

2. Information We Collect

gm108 collects various types of personal information to provide you with our services, ensure platform security, comply with legal obligations, and improve your user experience. The information we collect falls into the following categories:

2.1 Information You Provide Directly

When you register an account, use our services, or communicate with us, you provide information directly to gm108, including:

• Account Registration Data: Full name, date of birth, email address, mobile phone number, residential address within Indonesia, username, and password.
• Identity Verification Documents (KYC): Copies of your Indonesian National Identity Card (KTP), selfie photographs for identity confirmation, proof of address documents, and any additional verification documents requested to comply with anti-money laundering regulations.
• Payment Information: Bank account details (bank name, account number, account holder name), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja account information), and transaction histories.
• Communication Data: Messages, emails, live chat transcripts, support tickets, feedback submissions, and any other communications you send to gm108 customer support or via our platform.
• Marketing Preferences: Your consent to receive promotional communications, newsletter subscriptions, and marketing preferences.

2.2 Information Collected Automatically

When you access and use the gm108 platform, we automatically collect certain technical and usage data, including:

• Device Information: Device type (desktop, mobile, tablet), operating system, browser type and version, screen resolution, device identifiers (IP address, device ID), and mobile network information.
• Usage Data: Pages visited, features accessed, time spent on the platform, clickstream data, referral sources, search queries, game play history, betting history, deposit and withdrawal activities, and session durations.
• Location Data: IP-based geolocation to verify that you are accessing the platform from within Indonesia, as required by our licensing and regulatory obligations.
• Cookies and Tracking Technologies: Information collected through cookies, web beacons, pixels, and similar technologies to recognize your browser, remember your preferences, and analyze platform usage patterns. See Section 6 for detailed information about cookies.

2.3 Information from Third-Party Sources

In certain circumstances, we may receive information about you from third-party sources, including:

• Payment Providers: Transaction confirmation, payment status, and fraud prevention data from Indonesian banks (BCA, BRI, BNI, Mandiri, etc.) and e-wallet services.
• Identity Verification Services: Age verification, identity confirmation, and fraud detection data from third-party KYC verification providers.
• Marketing Partners: Referral information if you were introduced to gm108 through a marketing campaign or affiliate partner.

3. How We Use Your Personal Data

gm108 processes your personal information for the following purposes, all of which are necessary to provide our services, comply with legal obligations, and improve your user experience:

3.1 Service Provision and Account Management

• Create and manage your user account
• Verify your identity and age (21+ requirement) through KYC procedures
• Process deposits, withdrawals, and financial transactions
• Provide access to gaming and betting services
• Process bets, wagers, and game participation
• Calculate and distribute winnings
• Manage bonuses, promotions, and loyalty rewards
• Provide customer support and respond to your inquiries

3.2 Security, Fraud Prevention, and Legal Compliance

• Detect, prevent, and investigate fraud, cheating, collusion, money laundering, and other prohibited activities
• Monitor for underage gambling and enforce age restrictions
• Comply with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations
• Fulfill legal obligations under Indonesian law and international gaming regulations
• Respond to legal requests, court orders, or government inquiries
• Enforce our Terms and Conditions and protect our legal rights
• Maintain platform security and protect against cyberattacks

3.3 Platform Improvement and Analytics

• Analyze user behavior and preferences to improve platform functionality
• Conduct research and statistical analysis to enhance user experience
• Test new features and optimize existing services
• Monitor platform performance and troubleshoot technical issues
• Generate aggregated, anonymized reports for business intelligence

3.4 Marketing and Communications

• Send promotional offers, bonuses, and personalized recommendations (only if you have opted in)
• Notify you about new games, features, and platform updates
• Send transactional notifications (deposit confirmations, withdrawal status, account alerts)
• Conduct customer satisfaction surveys

You can opt out of marketing communications at any time by adjusting your account preferences or clicking the unsubscribe link in emails.

4. How We Share Your Personal Data

gm108 does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your data with the following categories of recipients in specific circumstances:

4.1 Service Providers and Business Partners

We work with trusted third-party service providers who assist us in operating the platform, including:

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to process deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and age verification services to confirm your identity and compliance with age restrictions.
• Gaming Software Providers: Game developers and platform providers who deliver casino games, live dealer services, and sports betting infrastructure.
• Cloud Hosting and IT Infrastructure: Servers, databases, and technical infrastructure providers that store and process platform data securely.
• Customer Support Tools: Live chat platforms, helpdesk software, and communication tools used to provide customer service.
• Analytics and Marketing Services: Tools to analyze user behavior, measure marketing campaign effectiveness, and optimize platform performance.

All service providers are contractually obligated to protect your data and use it only for the specific purposes we authorize.

4.2 Legal and Regulatory Authorities

We may disclose your personal information to government authorities, regulators, law enforcement agencies, or courts when required by law or when necessary to:

• Comply with legal obligations, court orders, or regulatory requests
• Investigate suspected fraud, money laundering, or illegal activity
• Protect the rights, property, or safety of gm108, our users, or the public
• Enforce our Terms and Conditions or defend against legal claims

4.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of assets, your personal information may be transferred to the acquiring entity, subject to the same privacy protections outlined in this policy.

5. How We Protect Your Personal Data

gm108 takes data security seriously and implements industry-standard technical and organizational measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction.

5.1 Technical Security Measures

• Encryption: All data transmitted between your device and our servers is protected by 256-bit SSL/TLS encryption, the same standard used by banks.
• Secure Servers: Personal data is stored on secure servers located in protected data centers with restricted physical access.
• Firewalls and Intrusion Detection: Advanced firewall systems and intrusion detection/prevention technologies monitor and block unauthorized access attempts.
• Password Protection: User passwords are hashed and salted using cryptographic algorithms, meaning even gm108 staff cannot view your original password.
• Regular Security Audits: We conduct periodic security assessments, vulnerability scans, and penetration testing to identify and address potential risks.

5.2 Organizational Security Measures

• Access Controls: Only authorized personnel with a legitimate business need can access personal data, and all access is logged and monitored.
• Employee Training: All staff members receive data protection and security awareness training.
• Confidentiality Agreements: Employees and contractors are bound by strict confidentiality obligations.
• Data Minimization: We collect and retain only the data necessary to provide our services and comply with legal requirements.

While we implement robust security measures, no system is completely impenetrable. You also play a role in protecting your account by choosing a strong password, not sharing your login credentials, and promptly reporting any suspicious activity.

6. Cookies and Tracking Technologies

The gm108 platform uses cookies and similar tracking technologies to enhance your user experience, analyze platform usage, and deliver personalized content. A cookie is a small text file stored on your device that helps us recognize your browser and remember your preferences.

6.1 Types of Cookies We Use

• Essential Cookies: Necessary for the platform to function properly. These cookies enable core features like account login, session management, and security.
• Performance Cookies: Collect anonymous data about how users interact with the platform, helping us identify issues and optimize performance.
• Functionality Cookies: Remember your preferences (language, region, display settings) to provide a personalized experience.
• Marketing Cookies: Track your browsing activity to deliver relevant promotional content and measure marketing campaign effectiveness.

6.2 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to block or delete cookies, though disabling essential cookies may affect platform functionality. You can also adjust your preferences for marketing cookies through your account settings on the gm108 platform.

7. Your Privacy Rights

As a gm108 user, you have certain rights regarding your personal data, subject to applicable Indonesian data protection laws:

• Right to Access: Request a copy of the personal information we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete personal data.
• Right to Erasure: Request deletion of your personal data, subject to legal retention obligations.
• Right to Restriction: Request limitation of processing in certain circumstances.
• Right to Data Portability: Request transfer of your data to another service provider in a structured, machine-readable format.
• Right to Object: Object to processing of your data for marketing purposes or based on legitimate interests.
• Right to Withdraw Consent: Withdraw consent for data processing activities that require your consent (does not affect the lawfulness of processing before withdrawal).

To exercise any of these rights, please contact our Data Protection Officer using the contact details provided in Section 12.

8. Data Retention

gm108 retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements.

• Active Accounts: Data is retained for the duration of your active account membership.
• Closed Accounts: After voluntary account closure, we retain certain data for up to 5 years to comply with financial record-keeping regulations, anti-money laundering requirements, and to resolve any outstanding disputes.
• Legal Obligations: Data required for legal, regulatory, tax, or accounting purposes is retained for the period mandated by Indonesian law.
• Marketing Data: If you opt out of marketing communications, we retain a record of your opt-out preference to ensure we do not contact you again.

9. International Data Transfers

While gm108 primarily operates within Indonesia and serves Indonesian users, some of our service providers and technical infrastructure may be located outside Indonesia. When personal data is transferred internationally, we ensure appropriate safeguards are in place, including:

• Contractual data protection clauses with third-party processors
• Data transfer agreements compliant with international standards
• Selection of service providers with strong data protection commitments

10. Children's Privacy

The gm108 platform is strictly intended for users aged 21 years or older. We do not knowingly collect personal information from individuals under 21 years of age. If we discover that we have inadvertently collected data from a minor, we will immediately delete such information and terminate the associated account.

Parents and guardians are encouraged to monitor their children's internet usage and use parental control tools to prevent minors from accessing online gaming platforms.

11. Changes to This Privacy Policy

gm108 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. When we make material changes, we will notify users via email, platform notification, or by posting a prominent notice on our website.

Your continued use of the gm108 platform after any changes indicates your acceptance of the revised Privacy Policy. We encourage you to review this page periodically to stay informed about how we protect your personal information.

12. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or how gm108 handles your personal data, please contact our Data Protection Officer:

• Email: [email protected] (Subject line: "Privacy Inquiry")
• Live Chat: Available 24/7 on the gm108 platform
• Response Time: We aim to respond to all privacy-related inquiries within 5 business days

For general customer support inquiries unrelated to privacy, please use our standard support channels.

Last Updated: January 2026. This Privacy Policy was last revised on January 1, 2026. Previous versions are available upon request.