Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal information collected by icb138 through our website (icb138.cam), mobile applications, customer support channels, and any other platforms or services we operate. This policy covers Indonesian residents who access our gaming platform for sports betting, live casino games, slot machines, and related entertainment services. icb138 acts as the data controller for all personal information collected through our platform, meaning we determine the purposes and means of processing your personal data. This policy should be read in conjunction with our Terms & Conditions, which govern the overall use of icb138 services.

2. Information We Collect

icb138 collects various categories of personal information necessary to provide gaming services, verify identity, process payments, prevent fraud, and fulfill legal obligations. The information we collect includes:

2.1 Information You Provide Directly

• Account Registration Data: When you create an icb138 account, we collect your full legal name (as appears on your KTP - Kartu Tanda Penduduk), date of birth, gender, email address, mobile phone number, residential address (street, city, province, postal code), and chosen username and password.
• Identity Verification Documents: For KYC (Know Your Customer) compliance, we collect copies of government-issued identification documents including your Indonesian KTP showing your photograph, ID number, and date of birth. We may also collect passport, driver's license, or other identity documents if KTP is unavailable.
• Financial Information: We collect bank account details (bank name, account number, account holder name) for Indonesian banks such as BCA, BRI, BNI, Mandiri, CIMB Niaga, and OCBC NISP. For e-wallet transactions, we collect your OVO, DANA, GoPay, ShopeePay, or LinkAja account identifiers. We do not store full credit card numbers but may retain the last 4 digits for transaction reference.
• Transaction History: Complete records of all deposits, withdrawals, wagers, wins, losses, bonus claims, and account balance changes are maintained for accounting, dispute resolution, and regulatory compliance purposes.
• Communications: When you contact customer support via live chat, email, WhatsApp, or phone, we record and store the content of those communications including your questions, complaints, feedback, and our responses.
• Responsible Gaming Settings: If you set deposit limits, loss limits, session time limits, or activate self-exclusion, we maintain records of these settings and any changes you make.

2.2 Information We Collect Automatically

• Device Information: We automatically collect information about the device you use to access icb138 including device type (mobile, tablet, desktop), operating system (Android, iOS, Windows, macOS), browser type and version, screen resolution, and device identifiers.
• Log Data: Our servers automatically record log information including your IP address, access times and dates, pages viewed, time spent on pages, navigation paths through the platform, and referring URLs (the site you came from before visiting icb138).
• Location Data: We collect general geographic location data derived from your IP address to verify you are accessing our platform from within Indonesia. We may request permission to access more precise GPS location data on mobile devices for additional verification.
• Cookies and Similar Technologies: We use cookies (small text files stored on your device), web beacons, pixel tags, and similar tracking technologies to recognize returning users, maintain login sessions, remember preferences, analyze platform usage patterns, and deliver personalized content. For detailed information, see Section 9 (Cookies and Tracking Technologies).
• Gameplay Data: We track detailed gameplay information including games played, bet amounts, win/loss records, game session durations, betting patterns, and gameplay statistics for fraud detection, game performance analysis, and personalized recommendations.

2.3 Information from Third Parties

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay) confirm transaction completion and may provide information about payment failures or disputes.
• Identity Verification Services: Third-party identity verification services may provide information confirming or denying the authenticity of submitted identity documents.
• Fraud Prevention Services: We work with specialized fraud detection companies that provide risk scores and alerts about potentially fraudulent accounts or transactions based on shared industry databases.

3. How We Use Your Information

icb138 uses collected personal information for the following specific purposes:

3.1 Providing Gaming Services

• Creating and managing your gaming account with secure login credentials
• Processing deposits and withdrawals through Indonesian payment methods
• Facilitating wagers on sports betting markets, live casino games, slot machines, and other gaming products
• Crediting winnings and debiting losses in accordance with game rules and betting outcomes
• Providing access to game history, transaction records, and account statements
• Administering bonuses, promotions, and loyalty rewards programs

3.2 Identity Verification and Fraud Prevention

• Verifying you are 21 years of age or older and legally eligible to use gaming services
• Confirming your identity matches the name on payment accounts to prevent fraud
• Detecting multiple accounts, bonus abuse, collusion, and other prohibited activities
• Monitoring betting patterns for signs of match-fixing, insider betting, or manipulation
• Screening against databases of self-excluded players and excluded jurisdictions
• Investigating suspicious transactions that may indicate money laundering or terrorist financing

3.3 Customer Support and Communication

• Responding to inquiries, complaints, and support requests via live chat, email, or WhatsApp
• Sending transactional emails about deposits, withdrawals, account changes, and security alerts
• Providing Indonesian-speaking customer service during WIB business hours
• Resolving disputes related to bets, payments, or account access
• Sending important service announcements about platform maintenance, terms updates, or policy changes

3.4 Platform Improvement and Personalization

• Analyzing usage patterns to improve platform navigation, game selection, and user interface design
• Recommending games and betting markets based on your preferences and gameplay history
• Testing new features, promotional offers, and platform improvements with selected user groups
• Optimizing platform performance, loading speeds, and mobile responsiveness
• Developing new products and services tailored to Indonesian player preferences

3.5 Marketing and Promotional Communications

With your consent, we may send marketing communications including:

• Promotional offers, bonus opportunities, and exclusive VIP rewards via email or SMS
• Information about new games, features, and platform enhancements
• Invitations to tournaments, competitions, and special events
• Seasonal promotions tied to Indonesian holidays (Idul Fitri, Hari Kemerdekaan, etc.)

You may opt out of marketing communications at any time by clicking the unsubscribe link in emails, replying STOP to SMS messages, or adjusting preferences in your account settings. Opting out of marketing does not affect essential transactional communications.

3.6 Legal Compliance and Safety

• Complying with Indonesian laws, regulations, and international gaming standards
• Responding to lawful requests from government authorities, regulators, or law enforcement
• Enforcing our Terms & Conditions and investigating potential violations
• Protecting icb138, our employees, and other users from fraud, abuse, or security threats
• Maintaining records for auditing, accounting, and tax reporting requirements
• Supporting responsible gaming initiatives and preventing underage gambling

4. How We Share Your Information

icb138 does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information with the following categories of recipients for specific legitimate purposes:

4.1 Service Providers and Business Partners

We engage trusted third-party companies to perform services on our behalf, including:

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) receive payment information necessary to process deposits and withdrawals.
• Game Providers: Evolution Gaming, Pragmatic Play, Microgaming, NetEnt, Ezugi, Spribe, and other game studios receive minimal gameplay data required to deliver their games and verify outcomes.
• Identity Verification Services: Specialized KYC providers receive copies of identity documents to authenticate their validity and confirm your age.
• Customer Support Tools: Live chat software providers and email service platforms process support communications to facilitate efficient customer service.
• Cloud Hosting Providers: Secure data centers host our servers and databases where your encrypted information is stored.
• Analytics Services: Platform analytics tools receive aggregated, anonymized usage data to help us understand user behavior patterns.

All third-party service providers are contractually obligated to use your information only for the specific services they provide to icb138, maintain appropriate security measures, and comply with applicable data protection laws. We conduct due diligence before engaging service providers and regularly review their data handling practices.

4.2 Legal and Regulatory Requirements

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

• Comply with legal obligations, court orders, subpoenas, or lawful requests from Indonesian government authorities
• Respond to regulatory inquiries from gaming commissions or financial authorities
• Cooperate with law enforcement investigations into criminal activity, fraud, or money laundering
• Enforce our Terms & Conditions or other agreements
• Protect the rights, property, or safety of icb138, our employees, or other users
• Prevent fraud, security threats, or technical issues that could harm the platform or users

4.3 Business Transfers

In the event icb138 is involved in a merger, acquisition, corporate restructuring, sale of assets, or bankruptcy proceeding, your personal information may be transferred to the acquiring entity or successor organization. You will be notified via email or prominent platform notice before your information is transferred and becomes subject to a different privacy policy.

4.4 With Your Consent

We may share your information with third parties when you explicitly consent to such sharing. For example, if you opt into a specific promotional partnership or integration with third-party services, we will share only the information necessary for that partnership after obtaining your informed consent.

5. How We Protect Your Information

icb138 implements comprehensive technical and organizational security measures to protect your personal information against unauthorized access, loss, destruction, alteration, or disclosure:

5.1 Technical Security Measures

• SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using industry-standard 256-bit SSL (Secure Sockets Layer) encryption, the same technology used by major banks for online banking.
• Data Encryption at Rest: Personal information stored in our databases is encrypted using AES-256 encryption to protect against unauthorized access even if physical storage media is compromised.
• Secure Servers: Our infrastructure is hosted in secure, access-controlled data centers with 24/7 monitoring, fire suppression systems, backup power supplies, and physical security guards.
• Firewalls and Intrusion Detection: Advanced firewall systems and intrusion detection software monitor network traffic for suspicious activity and block unauthorized access attempts in real-time.
• Regular Security Audits: Independent third-party security firms conduct penetration testing and vulnerability assessments to identify and address potential security weaknesses.
• Tokenization: Sensitive payment information is tokenized, meaning we store only non-sensitive tokens rather than actual bank account numbers or card details.

5.2 Organizational Security Measures

• Access Controls: Employee access to personal data is restricted based on role and necessity. Only authorized personnel with legitimate business reasons can access specific categories of personal information.
• Employee Training: All staff members receive mandatory training on data protection principles, security best practices, and privacy obligations.
• Confidentiality Agreements: Employees, contractors, and service providers sign strict confidentiality agreements prohibiting unauthorized use or disclosure of personal information.
• Incident Response Plan: We maintain a comprehensive data breach response plan to quickly detect, contain, investigate, and remediate security incidents while notifying affected users as required by law.
• Secure Development Practices: Our development team follows secure coding standards and conducts code reviews to prevent vulnerabilities like SQL injection, cross-site scripting, and other common exploits.

5.3 Your Security Responsibilities

While icb138 implements robust security measures, you also play a critical role in protecting your account:

• Choose a strong, unique password combining uppercase, lowercase, numbers, and special characters
• Never share your password with anyone, including people claiming to be icb138 staff
• Enable two-factor authentication (2FA) for an additional security layer
• Log out after each session, especially on shared or public devices
• Avoid accessing your account over public Wi-Fi networks without a VPN
• Immediately report suspicious account activity or unauthorized access to customer support
• Keep your registered email account secure, as it can be used for password resets

6. Data Retention

icb138 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 include:

• Active Accounts: Information for active accounts is retained indefinitely while your account remains open and active.
• Inactive Accounts: If your account remains inactive (no login, deposit, or wager) for 12 consecutive months, we may close the account and delete or anonymize personal information after providing 30 days' notice.
• Closed Accounts: After voluntary account closure, we retain essential information (name, ID number, transaction history) for 7 years to comply with Indonesian financial record-keeping requirements, tax laws, and anti-money-laundering regulations.
• Transaction Records: Financial transaction data (deposits, withdrawals, wagers) is retained for at least 7 years for accounting, auditing, and regulatory compliance purposes.
• Communications: Customer support communications are retained for 3 years for quality assurance and dispute resolution purposes.
• Marketing Data: If you opt out of marketing, we retain minimal information (email address, opt-out status) to honor your preference and prevent re-adding you to marketing lists.
• Legal Holds: Information subject to ongoing litigation, investigation, or regulatory inquiry is retained until the matter is resolved, regardless of standard retention periods.

After retention periods expire, we securely delete personal information or anonymize it so it can no longer be associated with you as an individual. Anonymized data may be retained indefinitely for statistical analysis and business intelligence purposes.

7. Your Privacy Rights

Indonesian residents have specific rights regarding their personal information. icb138 respects these rights and provides mechanisms to exercise them:

7.1 Right to Access

You have the right to request confirmation of what personal information icb138 holds about you and obtain a copy of that information. You can access much of this information directly through your account dashboard (transaction history, personal details, gameplay records). For additional information not available through your account, submit a request to [email protected] with "Data Access Request" in the subject line. We will respond within 30 days with a comprehensive report of your personal data.

7.2 Right to Correction

If your personal information is inaccurate, incomplete, or outdated, you have the right to request correction. You can update your email address, phone number, and residential address directly in your account settings. For changes to your legal name or date of birth (which require KYC verification), contact customer support with supporting documentation.

7.3 Right to Deletion

You may request deletion of your personal information, subject to legal exceptions. We will comply with deletion requests except where we must retain information to:

• Complete transactions or fulfill contractual obligations
• Comply with legal requirements such as tax record-keeping or anti-money-laundering laws
• Detect and prevent fraud, security incidents, or other prohibited activities
• Defend against legal claims or enforce our rights under our Terms & Conditions

To request account closure and data deletion, contact [email protected] with "Account Closure Request" in the subject line. Verify your identity, confirm your withdrawal of all funds, and acknowledge any outstanding obligations. We will process your request within 30 days.

7.4 Right to Object and Restrict Processing

You have the right to object to certain types of data processing, particularly direct marketing. You can opt out of promotional emails, SMS messages, and notifications through account settings or by clicking unsubscribe links. You may also request restriction of processing in specific circumstances, such as while disputing data accuracy or during investigation of a complaint.

7.5 Right to Data Portability

Upon request, icb138 will provide your personal information in a structured, commonly used, machine-readable format (such as CSV or JSON) so you can transmit it to another service provider. This right applies to information you provided to us with your consent or pursuant to a contract.

7.6 Right to Withdraw Consent

Where we process your personal information based on consent (such as for marketing communications), you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing based on consent before withdrawal. To withdraw consent, adjust your account preferences or contact customer support.

7.7 Exercising Your Rights

To exercise any privacy rights, contact icb138 at [email protected] with a clear description of your request. Include your full name, account username, and registered email address. We may request additional information to verify your identity before processing requests that involve access to or deletion of personal information. We will respond to verified requests within 30 days. There is no fee for exercising your rights unless your request is manifestly unfounded or excessive, in which case we may charge a reasonable administrative fee.

8. International Data Transfers

icb138 primarily serves Indonesian residents and processes data within Indonesia. However, some of our third-party service providers (such as game providers, cloud hosting companies, and payment processors) may be located outside Indonesia, including in jurisdictions such as Singapore, Hong Kong, the Philippines, the European Union, or the United States. When we transfer personal information to countries outside Indonesia, we implement appropriate safeguards to ensure your data receives adequate protection:

• Standard contractual clauses approved by Indonesian data protection authorities
• Verification that the recipient country provides adequate data protection laws
• Binding corporate rules for intra-group transfers within corporate families
• Your explicit consent for specific transfers where other safeguards are not available

By using icb138 services, you acknowledge and consent to the transfer of your personal information to jurisdictions outside Indonesia under these protective measures.

9. Cookies and Tracking Technologies

9.1 What Are Cookies?

Cookies are small text files stored on your device (computer, smartphone, tablet) by websites you visit. They allow the website to remember your actions, preferences, and device information over time, enhancing functionality and user experience. icb138 uses cookies and similar technologies including web beacons, pixel tags, and local storage.

9.2 Types of Cookies We Use

Cookie Type	Purpose	Duration
Essential Cookies	Enable core functionality like login sessions, account access, and secure transactions. Cannot be disabled.	Session or 30 days
Functional Cookies	Remember preferences such as language, currency display, and display settings.	30-365 days
Analytics Cookies	Collect aggregated data about platform usage, page views, and navigation patterns to improve services.	30-730 days
Marketing Cookies	Track your interests to deliver personalized promotional offers and advertisements.	30-365 days

9.3 Managing Cookies

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies or alert you when cookies are being sent. Visit your browser's help section for instructions on managing cookies (Chrome, Firefox, Safari, Edge each have different procedures). Note that disabling cookies may limit your ability to use certain icb138 features, particularly login functionality and personalized experiences. You can also opt out of third-party analytics cookies through tools like Google Analytics Opt-out Browser Add-on.

10. Children's Privacy

icb138 services are intended exclusively for adults 21 years of age and older. We do not knowingly collect personal information from individuals under 21. Our registration process requires date of birth verification, and KYC procedures confirm age through government-issued identity documents (KTP). If we discover that we have inadvertently collected information from someone under 21, we will immediately delete that information, close the account, void any wagers, and forfeit any funds. Parents or guardians who believe their child has provided information to icb138 should contact us immediately at [email protected] so we can take appropriate action.

11. Changes to This Privacy Policy

icb138 reserves the right to modify, update, or replace this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes that significantly affect your rights or how we handle personal information, we will notify you by:

• Sending an email notification to your registered email address at least 30 days before the changes take effect
• Displaying a prominent notice on the icb138 platform homepage and login screen
• Requiring you to review and accept the updated policy before continuing to use services

The "Last Updated" date at the top of this document indicates when the most recent revision was published. We encourage you to periodically review this Privacy Policy to stay informed about how we protect your information. Continued use of icb138 services after changes become effective constitutes acceptance of the updated policy.

12. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact icb138 through the following channels:

• Email: [email protected] (monitored 24/7, typical response within 1-3 hours)
• Subject Line: Use "Privacy Inquiry" or "Data Protection Question" for privacy-specific matters
• Live Chat: Available after login for immediate assistance (2-5 minute average response time)
• WhatsApp: +62 812 3456 7890 (business hours 08:00-23:00 WIB)

Our Indonesian-speaking data protection team will investigate your inquiry and respond within 30 days with a detailed explanation or resolution. If you are unsatisfied with our response, you have the right to lodge a complaint with Indonesian data protection authorities or consumer protection agencies.