Privacy Policy

1. Introduction and Scope

pay188 ("we", "us", "our") operates the online betting and casino platform accessible at https://pay188.cam. We are committed to protecting the privacy and personal data of every user who registers, browses, or interacts with our platform. This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and what rights you have with respect to your own information.

This Policy applies to all personal data collected through the pay188 website, our mobile-optimised interface, customer support channels, marketing communications, and any other service provided under the pay188 brand to users in Indonesia. It is supplementary to, and should be read alongside, our Terms & Conditions.

pay188 primarily serves users who are residents of Indonesia. We recognise that Indonesian users interacting with our platform — whether placing bets on BRI Liga 1, participating in togel (Indonesia's traditional numbers lottery) draws, or engaging with live casino tables — share personal and financial data with us, and we take our responsibility to protect that data seriously.

2. Definitions

For the purposes of this Privacy Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person — including, but not limited to, your name, identification number, location data, email address, or any factor specific to your physical, economic, or online identity.
• "Processing" means any operation performed on personal data, including collection, recording, organisation, storage, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" means pay188, the entity that determines the purposes and means of processing personal data.
• "Data Processor" means any third party that processes personal data on behalf of pay188 under a binding data-processing agreement.
• "User" or "you" means any individual who accesses or uses the pay188 platform, whether or not they have registered an account.
• "Account" means a registered membership account created by a User on the pay188 platform.
• "KYC" (Know Your Customer) means the identity and document verification process required by pay188 to confirm a User's identity before certain actions (such as withdrawals) are permitted.

3. Information We Collect

3.1 Information You Provide Directly

When you register an account, make a deposit, request a withdrawal, contact customer support, or otherwise interact with pay188, we may collect the following categories of personal data:

• Identity Data: Full legal name, date of birth, gender, nationality, and a copy of your government-issued identification document (Indonesian KTP, passport, or driver's licence).
• Contact Data: Email address, mobile phone number, and residential address in Indonesia (including city, province, and postcode).
• Financial Data: Bank account details (including account holder name, bank name — such as BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP — and account number), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja), deposit and withdrawal history, and transaction records.
• Account Data: Username, encrypted password, account preferences, communication settings, and self-imposed responsible gaming limits.
• Support Data: Records of communications with our customer support team, including live chat transcripts, email correspondence, and the content of any complaints or queries.

3.2 Information Collected Automatically

When you access or use the pay188 platform, our systems automatically collect certain technical and behavioural data:

• Device and Browser Data: IP address, browser type and version, operating system, device type (mobile or desktop), screen resolution, and language settings.
• Usage Data: Pages visited, games played (including bet amounts, game types, and outcomes), session duration, click-through patterns, search queries within the platform, and navigation paths.
• Location Data: General geographic location inferred from your IP address (city or region level). We do not collect precise GPS location data unless explicitly requested and consented to.
• Cookies and Tracking Data: Data collected through cookies, web beacons, pixel tags, and similar tracking technologies as described in Section 7 of this Policy.

3.3 Information from Third Parties

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

• Identity verification service providers used to confirm the authenticity of your KYC documents.
• Payment processors and banking partners (such as BCA, BRI, BNI, Mandiri, or e-wallet providers) to verify the status of transactions.
• Fraud prevention and anti-money laundering screening services.
• Publicly available sources, where relevant to regulatory compliance or fraud investigation.

4. How We Use Your Information

pay188 uses the personal data we collect for the following purposes:

Purpose	Categories of Data Used
Creating and managing your account	Identity Data, Contact Data, Account Data
Processing deposits and withdrawals	Financial Data, Identity Data, KYC records
Verifying your identity (KYC)	Identity Data, Financial Data
Detecting and preventing fraud and money laundering	All data categories as relevant
Providing customer support	Contact Data, Account Data, Support Data
Personalising your platform experience	Usage Data, Account Data
Sending service notifications and updates	Contact Data, Account Data
Responsible gaming monitoring and enforcement	Account Data, Usage Data, Financial Data
Analytics and platform improvement	Usage Data, Device and Browser Data (aggregated)
Marketing and promotional communications (with consent)	Contact Data, Account Data, Usage Data
Complying with legal and regulatory obligations	All data categories as relevant

5. Legal Bases for Processing

pay188 processes your personal data on the following legal grounds:

• Contractual Necessity: Processing required to perform our contract with you — principally to operate your account, process transactions, and deliver our betting and gaming services.
• Legal Obligation: Processing required to comply with applicable laws, including anti-money laundering regulations, KYC requirements, and responsible gaming obligations.
• Legitimate Interests: Processing for purposes such as fraud prevention, platform security, analytics, and improving our services — where those interests are not overridden by your rights and interests.
• Consent: Processing for direct marketing communications, non-essential cookies, or any other purpose where we have sought and obtained your express consent. You may withdraw this consent at any time by contacting customer support or updating your account preferences.

6. Sharing and Disclosure of Data

6.1 Third-Party Service Providers

pay188 shares personal data with trusted third-party service providers who process data on our behalf under binding data-processing agreements. These providers include identity verification services, payment processors (including Indonesian banking partners such as BCA, BRI, BNI, and Mandiri), e-wallet providers (OVO, DANA, GoPay), fraud screening services, cloud hosting and data-centre providers, game platform vendors (including Evolution Gaming, Pragmatic Play, Microgaming, Spribe), and customer support software providers. These parties are permitted to use your data only for the specific purposes for which it was shared and must maintain appropriate security measures.

6.2 Legal and Regulatory Disclosure

pay188 may disclose your personal data to law enforcement authorities, regulatory bodies, courts, or other government agencies where we are required to do so by law, court order, or regulatory directive — including in connection with anti-money laundering investigations, responsible gaming enforcement, or tax-reporting obligations.

6.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of all or substantially all of pay188's assets, personal data held by pay188 may be transferred to the acquiring entity. You will be notified of any such transfer and the applicable privacy terms via a prominent notice on our website or via email.

6.4 No Sale of Personal Data

pay188 does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes.

7. Cookies and Tracking Technologies

pay188 uses cookies and similar technologies to operate the platform, remember your preferences, maintain your login session, and analyse platform usage. Cookies are small text files stored on your device by your web browser.

We use the following categories of cookies:

• Strictly Necessary Cookies: Essential to the operation of the platform. Without these cookies, features such as account login, session maintenance, and transaction processing cannot function. These cookies cannot be disabled.
• Functional Cookies: Remember your preferences and settings (such as language preferences, responsible gaming limit configurations, and recently played games) to personalise your experience.
• Analytics Cookies: Collect anonymised or pseudonymised data about how users interact with the platform — pages visited, session duration, and navigation patterns — to help us improve the platform experience. We use aggregated, non-identifiable data for these purposes.
• Marketing Cookies: Used to deliver relevant promotional content based on your interests and browsing behaviour, where you have consented to receive marketing communications from pay188.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the pay188 platform.

8. Data Retention

pay188 retains personal data only for as long as necessary to fulfil the purposes described in this Policy, unless a longer retention period is required by law. Specific retention periods include:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years after account closure, to comply with anti-money laundering and regulatory audit requirements.
• Financial and Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in accordance with Indonesian financial record-keeping obligations.
• KYC and Identity Documents: Retained for a minimum of five (5) years from the date of verification, or longer if required by applicable regulations.
• Customer Support Records: Retained for three (3) years from the date of the interaction.
• Marketing Data: Retained until you withdraw your consent to receive marketing communications.
• Analytics Data: Retained in aggregated or anonymised form indefinitely for platform improvement purposes.

Upon expiration of the applicable retention period, personal data will be securely deleted or anonymised so that it can no longer be attributed to you.

9. Data Security

pay188 implements comprehensive technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption (TLS 1.3) on all data transmitted between your browser and our servers.
• Encryption of sensitive data at rest, including identity documents and financial records.
• Access controls limiting personal data access to authorised personnel on a need-to-know basis.
• Regular security audits and penetration testing by qualified third-party security professionals.
• Two-factor authentication (2FA) available to Users for account login protection.
• Secure, segregated server environments for production and testing systems.
• Staff training on data protection obligations and information security best practices.

While we take every reasonable precaution to protect your data, no method of transmission over the internet or electronic storage is entirely secure. We cannot guarantee absolute security but we commit to responding promptly to any security incident and notifying affected users where required by law.

10. Your Rights

Depending on applicable data protection laws, you may have the following rights with respect to your personal data held by pay188:

• Right of Access: You may request a copy of the personal data we hold about you and information about how it is processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you.
• 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 — subject to our legal retention obligations (see Section 8).
• Right to Restrict Processing: You may request that we limit how we use your personal data in certain circumstances.
• Right to Data Portability: You may request that we provide your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing conducted before withdrawal.

To exercise any of these rights, please contact our Data Privacy team at [email protected]. We will respond to all valid requests within 30 days. In some cases, we may need to verify your identity before processing your request.

11. Children's Privacy

pay188 does not knowingly collect personal data from individuals under the age of 21. Our platform is strictly intended for adults aged 21 and over. If we discover that personal data has been collected from a person under 21, we will delete that data immediately and close the associated account. If you believe we have inadvertently collected data from a minor, please contact us immediately at [email protected].

12. International Data Transfers

pay188 may transfer personal data to servers or service providers located outside Indonesia, including in jurisdictions that may not provide the same level of data protection as Indonesian law. In all such cases, we ensure that appropriate safeguards are in place — such as data-processing agreements incorporating standard contractual clauses — to protect your personal data in accordance with the standards described in this Policy.

13. Changes to This Privacy Policy

pay188 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable laws, or business operations. We will publish any material changes on this page with an updated "Last Updated" date. For significant changes affecting your rights, we will provide additional notice via email or a prominent notification on the platform. Continued use of pay188 services following the publication of changes constitutes your acceptance of the revised Policy.

14. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way pay188 handles your personal data, please contact our Data Privacy team through the following channels:

• Email: [email protected]
• Live Chat: Available 24/7 on the pay188 website (WIB, UTC+7)
• Response Time: We aim to respond to all privacy-related enquiries within 30 calendar days.