Privacy Policy

1. Introduction and Scope

aehoki ("we", "us", "our", "Platform") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, store, share, and protect information about you when you access or use our online gaming platform, including our website, mobile applications, and related services (collectively, the "Services").

This Privacy Policy applies to all users of aehoki Services, including visitors who browse our Platform without creating an account and registered players who maintain active gaming accounts. By accessing or using our Services, you acknowledge that you have read, understood, and consent to the data practices described in this Privacy Policy.

If you do not agree with the terms of this Privacy Policy, you must immediately cease using our Services and refrain from creating an account. We encourage you to read this Privacy Policy carefully and contact us if you have any questions or concerns about how we handle your personal information.

2. Information We Collect

aehoki collects various types of information to provide, maintain, improve, and secure our Services. The categories of information we collect include:

2.1 Information You Provide Directly

When you register for an account or use our Services, you voluntarily provide us with personal information, including:

• Account Registration Data: Full legal name, date of birth, gender, residential address, email address, mobile phone number, username, and password.
• Identity Verification Data: Government-issued identification documents (Indonesian National ID/KTP, passport, driver's license), proof of address documents, and selfie photographs for Know Your Customer (KYC) compliance.
• Financial Information: Bank account details (account number, bank name, account holder name), e-wallet information (OVO, DANA, GoPay account details), payment card information (processed securely through third-party payment processors), transaction history, deposit and withdrawal records.
• Communications: Messages you send to our Customer Support team via live chat, email, WhatsApp, or in-app messaging, including the content of your inquiries and our responses.
• Optional Profile Information: Profile picture, communication preferences, marketing consent status.

2.2 Information Collected Automatically

When you access or use our Services, we automatically collect certain technical and usage information through various technologies:

• Device Information: Device type, operating system and version, browser type and version, screen resolution, device identifiers (IMEI, device ID), mobile network information.
• Usage Data: Pages visited, features used, games played, bet history, session duration, clickstream data, referring and exit pages, timestamps of activities.
• Location Data: IP address (which may indicate your approximate geographic location), timezone settings, language preferences. We may request precise location data if required for regulatory compliance.
• Cookies and Similar Technologies: Information collected through cookies, web beacons, pixels, and similar tracking technologies to recognize your device, remember preferences, and analyze Platform usage patterns (see Section 9 for detailed information).

2.3 Information from Third-Party Sources

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

• Payment Processors: Transaction verification data from banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay) to confirm deposits and process withdrawals.
• Identity Verification Services: Results from third-party identity verification and fraud detection services used to comply with regulatory requirements and protect against fraudulent activity.
• Analytics Providers: Aggregated demographic and behavioral data to help us understand user preferences and improve Services.

3. How We Use Your Information

aehoki uses the information we collect for the following legitimate purposes:

3.1 Service Provision and Account Management

• Creating and managing your gaming account
• Processing deposits, withdrawals, and other financial transactions
• Enabling you to participate in games, place bets, and access all Platform features
• Calculating winnings, managing bonuses, and maintaining accurate account balances
• Providing customer support and responding to your inquiries
• Communicating important account information, terms updates, and service notifications

3.2 Compliance and Security

• Verifying your identity and age to ensure compliance with the 21+ requirement and Indonesian regulations
• Conducting Know Your Customer (KYC) and Anti-Money Laundering (AML) checks as required by law
• Detecting, preventing, and investigating fraudulent activity, security breaches, and Terms violations
• Enforcing our Terms and Conditions and protecting the integrity of our Services
• Complying with legal obligations, court orders, and regulatory requests
• Implementing responsible gaming measures and self-exclusion programs

3.3 Platform Improvement and Analytics

• Analyzing usage patterns to understand player behavior and preferences
• Improving Platform functionality, game offerings, and user experience
• Developing new features, products, and services tailored to Indonesian players
• Conducting research and statistical analysis to enhance Service quality
• Testing new technologies and optimizing Platform performance

3.4 Marketing and Communications (With Your Consent)

• Sending promotional offers, bonus notifications, and special event announcements
• Providing personalized game recommendations based on your playing history
• Informing you about tournaments, jackpots, and VIP tier benefits
• Conducting surveys to gather feedback on our Services

Note: You may opt out of marketing communications at any time by adjusting your account settings or contacting Customer Support. Opting out will not affect essential service communications required for account operation.

4. Legal Basis for Processing

aehoki processes your personal information based on the following legal grounds:

• Contractual Necessity: Processing is necessary to fulfill our contractual obligations under the Terms and Conditions, including account creation, transaction processing, and service delivery.
• Legal Obligation: Processing is required to comply with Indonesian law, international regulations, KYC/AML requirements, age verification mandates, and regulatory reporting obligations.
• Legitimate Interests: Processing serves our legitimate business interests in preventing fraud, ensuring Platform security, improving Services, and conducting business analytics, provided these interests do not override your fundamental privacy rights.
• Consent: For marketing communications and non-essential data uses, we obtain your explicit consent, which you may withdraw at any time without affecting the lawfulness of processing based on consent before withdrawal.

5. Information Sharing and Disclosure

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

5.1 Service Providers

We engage trusted third-party service providers to perform functions on our behalf, including:

• Payment Processors: Banks (BCA, BRI, BNI, Mandiri), e-wallet providers (OVO, DANA, GoPay), and payment gateway services that facilitate deposits and withdrawals.
• Identity Verification Providers: Third-party services that verify age, identity, and address information for KYC compliance.
• Hosting and Infrastructure Providers: Cloud service providers and data center operators that host our Platform and store data securely.
• Customer Support Tools: Live chat platforms, email services, and ticketing systems used to provide support.
• Analytics Providers: Services that help us understand usage patterns and improve Platform performance.

All service providers are contractually obligated to maintain data confidentiality, use information only for specified purposes, and implement appropriate security measures. They are prohibited from using your information for their own purposes.

5.2 Legal and Regulatory Authorities

We may disclose your information to government authorities, law enforcement agencies, regulators, and courts when:

• Required by applicable Indonesian law or regulation
• Responding to valid legal processes such as subpoenas, court orders, or government inquiries
• Necessary to protect aehoki's rights, property, or safety, or that of our users or the public
• Detecting, preventing, or addressing fraud, security issues, or technical problems
• Complying with regulatory reporting obligations related to gaming, AML, or financial crime prevention

5.3 Business Transfers

In the event of a merger, acquisition, asset sale, or other corporate transaction involving aehoki, your information may be transferred to the successor entity, subject to the same privacy protections outlined in this Policy.

5.4 With Your Consent

We may share your information with other parties when you have provided explicit consent for such disclosure.

6. Data Security and Protection

aehoki implements comprehensive technical, administrative, and physical security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. Our security practices include:

6.1 Technical Safeguards

• Encryption: All sensitive data, including passwords and financial information, is encrypted both in transit (using 256-bit SSL/TLS) and at rest (using AES-256 encryption).
• Firewalls and Intrusion Detection: Multi-layered firewall systems and real-time intrusion detection monitor for suspicious activity and prevent unauthorized access.
• Secure Authentication: Strong password requirements, account lockout mechanisms after failed login attempts, and optional two-factor authentication for enhanced account protection.
• Regular Security Audits: Periodic penetration testing, vulnerability assessments, and third-party security audits to identify and remediate potential weaknesses.

6.2 Administrative Safeguards

• Access Controls: Strict role-based access controls ensure that only authorized personnel with legitimate business needs can access personal information.
• Employee Training: All employees receive regular training on data protection, privacy principles, and security best practices.
• Confidentiality Agreements: Employees and contractors are bound by confidentiality obligations regarding user information.
• Incident Response Plan: Documented procedures for detecting, responding to, and recovering from data breaches or security incidents.

6.3 Physical Safeguards

• Data centers with restricted physical access, 24/7 monitoring, and environmental controls
• Secure disposal procedures for hardware and media containing personal information

Important Notice: While we employ industry-standard security measures, no method of transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and should immediately notify us if you suspect unauthorized account access.

7. Data Retention

aehoki retains your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Active Account Data: Retained for the duration of your account's active status plus the periods specified below.
• Transaction Records: Retained for a minimum of seven (7) years after the transaction date to comply with Indonesian financial record-keeping requirements and tax regulations.
• Identity Verification Documents: Retained for a minimum of five (5) years after account closure to meet KYC/AML compliance obligations.
• Communications Records: Retained for three (3) years to provide evidence of interactions and resolve potential disputes.
• Marketing Consent Records: Retained until you withdraw consent, plus a reasonable period to demonstrate compliance with consent requirements.

After the applicable retention period expires, we securely delete or anonymize your personal information in accordance with data protection best practices. Anonymized data that cannot be linked back to you may be retained indefinitely for statistical and research purposes.

8. Your Privacy Rights

aehoki respects your rights regarding your personal information. Depending on your location and applicable laws, you may have the following rights:

8.1 Right to Access

You have the right to request confirmation of whether we process your personal information and to obtain a copy of the personal data we hold about you. You can access most of your information directly through your account settings or by contacting Customer Support.

8.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You can update your profile information, contact details, and communication preferences directly in your account settings.

8.3 Right to Erasure ("Right to Be Forgotten")

Under certain circumstances, you have the right to request deletion of your personal information. This right is subject to legal and regulatory retention requirements (such as financial record-keeping obligations) and may be limited if deletion would impair our ability to comply with legal obligations, resolve disputes, or enforce agreements.

8.4 Right to Restrict Processing

You have the right to request restriction of processing of your personal information in specific situations, such as when you contest the accuracy of the data or object to processing based on legitimate interests.

8.5 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that data to another service provider where technically feasible.

8.6 Right to Object

You have the right to object to processing of your personal information for direct marketing purposes (which we will honor immediately) or processing based on legitimate interests (which we will cease unless we can demonstrate compelling legitimate grounds that override your interests).

8.7 Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing based on consent before withdrawal.

8.8 How to Exercise Your Rights

To exercise any of these rights, please contact us using the information in Section 13. We will respond to your request within thirty (30) days and may request additional information to verify your identity before processing your request. There is no fee for exercising these rights unless your request is manifestly unfounded, excessive, or repetitive.

9. Cookies and Tracking Technologies

aehoki uses cookies, web beacons, pixels, and similar tracking technologies to enhance your experience, analyze Platform usage, and deliver personalized content. A cookie is a small text file stored on your device that allows us to recognize you on subsequent visits.

Types of Cookies We Use:

• Essential Cookies: Necessary for Platform functionality, including account authentication, session management, and security features. These cannot be disabled without severely limiting functionality.
• Performance Cookies: Collect information about how you use our Platform, such as pages visited and errors encountered, to help us improve performance and user experience.
• Functionality Cookies: Remember your preferences (language, currency, display settings) to provide enhanced, personalized features.
• Targeting/Advertising Cookies: Track your browsing activity to deliver relevant promotional offers and measure advertising effectiveness.

You can control cookie settings through your browser preferences. However, disabling certain cookies may limit your ability to use some Platform features. Most browsers automatically accept cookies, but you can modify settings to decline cookies or receive notifications when cookies are being sent.

10. Third-Party Links and Services

Our Platform may contain links to third-party websites, applications, or services that are not operated or controlled by aehoki. This Privacy Policy does not apply to third-party sites. We are not responsible for the privacy practices or content of external sites. We encourage you to review the privacy policies of any third-party services you access through our Platform.

When you use third-party payment services (banks, e-wallets) to deposit or withdraw funds, those transactions are governed by the third party's privacy policy and terms of service. aehoki is not responsible for the data practices of these payment providers.

11. International Data Transfers

Your personal information may be transferred to, stored at, and processed in locations outside of Indonesia, including countries that may have different data protection laws. When we transfer data internationally, we implement appropriate safeguards to ensure your information receives adequate protection, including:

• Transferring data only to jurisdictions recognized as providing adequate protection
• Using standard contractual clauses approved by relevant authorities
• Implementing additional technical and organizational measures to protect data in transit and at rest

By using our Services, you acknowledge and consent to the transfer of your information to other countries for the purposes described in this Privacy Policy.

12. Changes to This Privacy Policy

aehoki 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, we will:

• Update the "Effective Date" at the top of this Policy
• Notify you via email or prominent notice on the Platform
• Provide a reasonable period for you to review the changes before they take effect

Your continued use of our Services after the effective date of the revised Privacy Policy constitutes your acceptance of the changes. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. If you do not agree with any changes, you must discontinue using our Services and close your account.

13. Contact Information

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, or if you wish to exercise your privacy rights, please contact us through the following channels:

• Data Protection Officer: [email protected]
• Customer Support Email: [email protected]
• 24/7 Live Chat: Available directly on the Platform
• WhatsApp: +62 812-3456-7890 (08:00 - 23:00 WIB)

We will respond to privacy-related inquiries within thirty (30) days. For urgent data protection concerns, please clearly mark your communication as "URGENT - Privacy Request" to ensure prompt attention.

If you believe we have not adequately addressed your privacy concerns, you have the right to lodge a complaint with the relevant Indonesian data protection authority or supervisory body in your jurisdiction.