Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes the personal data practices of pln86 ("Company", "we", "us", "our"), operator of the online gaming platform accessible at https://pln86.cam. It explains what personal information we collect from you, why we collect it, how we use it, with whom we share it, and what rights you hold in relation to it.

This Policy applies to all individuals who visit the Platform, register an Account, make use of any game or wagering service, or otherwise interact with pln86 in any capacity, including Indonesian players accessing our Platform from Jakarta, Surabaya, Bandung, Medan, Bali, Yogyakarta, and all other regions of Indonesia.

By registering an Account or continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you must discontinue use of the Platform and may request Account closure as described in our Terms and Conditions.

2 Definitions

For the purposes of this Policy, the following terms carry the meanings set out below:

• "Account" — the personal player account created by you on the Platform.
• "Controller" — pln86, the entity that determines the purposes and means of processing your personal data.
• "Cookie" — a small text file placed on your device by the Platform to support functionality, analytics, and personalization.
• "Data Subject" — you, the individual whose personal data is being processed.
• "Personal Data" — any information that identifies or can reasonably be used to identify you as a natural person, including your name, date of birth, contact details, financial information, IP address, and device identifiers.
• "Platform" — the website at https://pln86.cam and all associated services, games, and applications.
• "Processing" — any operation performed on personal data, including collection, storage, use, disclosure, or deletion.
• "Processor" — a third party that processes personal data on behalf of pln86 under a contractual data processing agreement.
• "Sensitive Data" — personal data requiring heightened protection, including government-issued identity numbers (NIK from KTP), financial account details, and documents submitted for KYC verification.

3 Data We Collect

pln86 collects personal data that is necessary to provide a safe, compliant, and personalized gaming experience. The categories of data we collect are described below.

3.1 Registration Data

When you create an Account, we collect your full legal name, date of birth, email address, Indonesian mobile phone number, chosen username, and preferred language settings.

3.2 Identity Verification (KYC) Data

To comply with our licensing obligations and prevent fraud and underage gambling, we may collect copies of government-issued identification documents (KTP, passport, or SIM), proof-of-address documents, selfie photographs holding the identity document, and bank account or e-wallet ownership verification.

3.3 Financial Data

We collect details necessary to process your deposits and withdrawals, including your bank name (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, or Bank Permata), bank account number, account holder name, and e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, or LinkAja). We do not store complete bank account credentials beyond what is required to process your transactions.

3.4 Transaction Data

We maintain a complete record of all deposits, withdrawals, bonus credits, wagering activity, game results, and account adjustments associated with your Account, denominated in Indonesian Rupiah (IDR / Rp).

3.5 Technical Data

We automatically collect technical data when you access the Platform, including your IP address, browser type and version, operating system, device type and identifiers, screen resolution, and approximate geographic location derived from IP address.

3.6 Behavioral Data

We collect information about how you interact with the Platform, including pages visited, games played, session duration, wagering frequency, promotional offers viewed, and customer support interactions.

3.7 Communications Data

We retain records of all communications between you and pln86, including live chat transcripts, email correspondence, and any documents you submit in support of a complaint or dispute.

Data Category	Examples	Primary Purpose
Registration Data	Name, email, phone number, date of birth	Account creation and management
KYC / Identity Data	KTP, passport, selfie, address proof	Age and identity verification, AML compliance
Financial Data	Bank account number, e-wallet ID	Processing deposits and withdrawals in IDR
Transaction Data	Deposit/withdrawal history, bet records	Account records, dispute resolution, regulatory reporting
Technical Data	IP address, device ID, browser type	Security monitoring, fraud detection
Behavioral Data	Games played, session length, click paths	Platform improvement, responsible gaming monitoring
Communications Data	Chat logs, emails, support tickets	Support, dispute resolution, quality assurance

4 How We Collect Data

4.1 Directly From You

The majority of personal data we hold is provided directly by you during Account registration, KYC verification, payment processing, form submissions, and communications with our support team.

4.2 Automatically

When you visit or use the Platform, we automatically collect technical and behavioral data through server logs, cookies, pixel tags, and similar tracking technologies embedded in the Platform's code.

4.3 From Third Parties

We may receive personal data from third-party service providers acting in support of our operations, including identity verification agencies that cross-reference the documents you submit, payment processors and banking partners who confirm transaction details, and fraud detection services that flag suspicious account activity. All third-party data suppliers are contractually bound to share data with us only for the specific purposes stated in this Policy.

5 Legal Basis for Processing

pln86 processes your personal data only where a valid legal basis exists. The legal bases we rely upon are as follows:

• Contractual Necessity: Processing required to deliver the services set out in our Terms and Conditions, including managing your Account, processing wagers, and handling deposits and withdrawals.
• Legal Obligation: Processing required to comply with our Curaçao eGaming license conditions, including KYC verification, anti-money-laundering record-keeping, and regulatory reporting.
• Legitimate Interests: Processing necessary for our legitimate business interests, including fraud prevention, security monitoring, Platform improvement, and responsible gaming program management, provided such interests are not overridden by your rights and freedoms.
• Consent: Processing for optional purposes, including the sending of promotional emails and the use of non-essential analytics cookies, which you may withdraw at any time.

6 How We Use Your Data

pln86 uses the personal data it holds for the following specific purposes:

• Creating and maintaining your Account and verifying your eligibility to use the Platform.
• Processing deposits in IDR from Indonesian bank accounts (BCA, BRI, BNI, Mandiri) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja), and processing withdrawal requests to verified accounts.
• Conducting identity and age verification to ensure all active Players are 21 years of age or older, in compliance with our licensing terms.
• Detecting and preventing fraudulent activity, account takeovers, money laundering, collusion, and other forms of abuse.
• Monitoring and improving our responsible gaming program, including identifying players who may be showing signs of problem gambling and proactively offering support tools.
• Sending transactional communications, including deposit confirmations, withdrawal notifications, and security alerts.
• Sending promotional communications, including bonus offers, tournament invitations, and seasonal promotions, where you have provided consent or have not opted out.
• Personalizing your experience on the Platform, including displaying games relevant to your preferences and regional context (e.g., BRI Liga 1 markets for Indonesian football fans).
• Analyzing Platform usage to improve game selection, interface design, payment processing speed, and customer support quality.
• Complying with legal obligations and responding to lawful requests from licensing authorities or law enforcement ag encies.
• Resolving disputes, enforcing our Terms and Conditions, and defending legal claims.

7 Data Sharing & Disclosure

pln86 does not sell, rent, or trade your personal data to any third party for commercial marketing purposes. We share personal data only in the limited circumstances described below, and only to the extent strictly necessary for the stated purpose.

7.1 Service Providers (Processors)

We engage trusted third-party companies to support the operation of the Platform under written data processing agreements that prohibit them from using your data for any purpose beyond the specific service they provide. These Processors include payment gateway and banking integration partners who facilitate IDR transfers with BCA, BRI, BNI, and Mandiri; identity verification and KYC service providers; cloud hosting and infrastructure providers; customer support platform operators; fraud detection and cybersecurity vendors; and game content providers such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Pocket Games Soft.

7.2 Regulatory and Legal Disclosure

We may disclose personal data to our Curaçao eGaming licensing authority, financial intelligence units, or law enforcement agencies where we are legally required or compelled to do so by applicable law, court order, or regulatory directive. Where permitted by law, we will notify you of such disclosure unless doing so would compromise an ongoing investigation.

7.3 Business Transfers

In the event that pln86 undergoes a merger, acquisition, restructuring, or sale of all or substantially all of its assets, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify you via email and a prominent notice on the Platform prior to any such transfer and will ensure that the receiving entity is bound by privacy obligations no less protective than those set out in this Policy.

7.4 With Your Consent

We may share your data with third parties for purposes not covered above where you have given your explicit prior consent to such sharing. You may withdraw that consent at any time by contacting our support team.

8 Data Retention

pln86 retains personal data only for as long as is necessary to fulfill the purpose for which it was collected or as required by applicable legal and regulatory obligations. The following retention periods apply:

Data Category	Retention Period	Reason
Account & Registration Data	Duration of Account + 5 years	Regulatory record-keeping obligations
KYC / Identity Documents	Duration of Account + 7 years	Anti-money-laundering legal requirements
Financial & Transaction Records	Duration of Account + 7 years	Financial audit and regulatory compliance
Technical & Log Data	12 months from collection	Security monitoring and fraud investigation
Communications Data	3 years from last interaction	Dispute resolution and quality assurance
Marketing Consent Records	Until consent withdrawn + 3 years	Demonstrating lawful basis for marketing

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized in accordance with our data destruction procedures. Anonymized, aggregated data may be retained indefinitely for statistical and analytical purposes, as it can no longer be used to identify any individual.

9 Data Security

pln86 takes the security of your personal data seriously and implements a comprehensive set of technical and organizational measures designed to protect it against unauthorized access, disclosure, alteration, or destruction.

9.1 Technical Measures

• All data in transit is encrypted using TLS 1.3 (256-bit AES encryption), the same standard used by major Indonesian banks including BCA and BNI for their online banking portals.
• Data at rest is encrypted using AES-256 on all production servers and backup storage systems.
• Access to production systems and databases is restricted to authorized personnel using multi-factor authentication and role-based access controls.
• Our infrastructure is protected by next-generation firewalls, intrusion detection systems, and continuous automated vulnerability scanning.
• All Platform software undergoes regular penetration testing by independent third-party security firms.

9.2 Organizational Measures

• All pln86 personnel who handle personal data receive mandatory data protection training before commencing their role and annually thereafter.
• Access to personal data is granted on a strict need-to-know basis, with all access events logged and subject to periodic review.
• All third-party service providers with access to personal data are vetted for security practices and bound by contractual data processing agreements.

9.3 Data Breach Response

In the event of a personal data breach that poses a risk to your rights and freedoms, pln86 will notify you without undue delay and in any case within 72 hours of becoming aware of the breach, providing details of the nature of the breach, the categories of data affected, and the steps we are taking to mitigate harm. We will also notify the relevant licensing authority as required.

10 Cookies & Tracking

pln86 uses cookies and similar tracking technologies to operate the Platform effectively, understand how it is used, and deliver a personalized experience. A cookie is a small text file stored in your browser when you visit our Platform.

10.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. They enable core features such as account login sessions, shopping cart functionality for deposits, and security tokens. These cookies cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, preferred game categories, and display options to provide a more convenient experience.
• Analytics Cookies: Collect anonymized data about how visitors use the Platform, including page views, session duration, and navigation paths. This data helps us improve the Platform's performance and content.
• Marketing Cookies: Used to track the effectiveness of promotional campaigns and, where you have consented, to display relevant offers based on your browsing behavior.

10.2 Managing Cookies

You can control non-essential cookies through your browser settings. Most modern browsers allow you to view, block, or delete cookies at any time. Please note that disabling certain functional cookies may affect the performance of the Platform and your ability to access some features. Instructions for managing cookies are available in your browser's help documentation.

11 Your Rights

As a data subject, you hold the following rights in relation to your personal data held by pln86. To exercise any of these rights, please contact us at [email protected] with the subject line "Data Rights Request – [Your Right]".

• Right of Access: You may request a copy of all personal data we hold about you, along with 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 purpose for which it was collected, subject to our legal retention obligations.
• Right to Restriction: You may request that we restrict processing of your data in certain circumstances, for example while a dispute is being resolved.
• Right to Data Portability: You may request that we provide your personal data in a structured, machine-readable format for transfer to another service provider.
• Right to Object: You may object to processing based on our legitimate interests, including direct marketing. We will cease such processing unless we can demonstrate compelling grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

We will respond to all valid data rights requests within 30 calendar days of receipt. Where a request is complex or numerous, we may extend this period by a further 30 days, notifying you of the extension and the reason for it.

12 Minors & Age Restrictions

The Platform is strictly intended for adults aged 21 years and over. pln86 does not knowingly collect, store, or process personal data belonging to individuals under the age of 21. Age verification is a mandatory step in our Account registration process and is rigorously enforced through our KYC program.

If you are a parent or guardian and have reason to believe that a person under 21 in your care has registered an Account or submitted personal data to pln86, please contact us immediately at [email protected]. Upon receiving a verified notification of this nature, we will promptly suspend the Account, delete the associated personal data, and return any deposited funds to the originating payment source.

We also employ technical measures including IP-based age screening and behavioral monitoring to identify accounts that may belong to underage individuals, supplemented by our mandatory document-based KYC process.

13 International Data Transfers

pln86 is headquartered under Curaçao eGaming jurisdiction. Your personal data may be processed on servers located outside Indonesia, including in data centers in the Netherlands, Singapore, or other countries where our infrastructure and service providers operate. These jurisdictions may have data protection laws that differ from those in Indonesia.

Where personal data is transferred outside of your country of residence, pln86 implements appropriate safeguards to ensure that your data receives a level of protection consistent with the standards described in this Policy. These safeguards include binding contractual clauses incorporated into our agreements with all data processors, and where applicable, reliance on adequacy decisions or equivalent cross-border data transfer mechanisms.

14 Third-Party Services

The Platform integrates content and services from third-party providers, including game studios (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, Pocket Games Soft), payment processors, and analytics platforms. When you interact with these integrated services, those providers may collect data directly from you in accordance with their own privacy policies, which are independent of this Policy.

pln86 is not responsible for the privacy practices of third-party game providers or external services accessed through our Platform. We encourage you to review the privacy policies of any third-party services you interact with. Our data processing agreements with all integrated providers require them to handle any personal data they access solely for the purpose of delivering the contracted service to pln86.

15 Policy Amendments

pln86 reserves the right to update or modify this Privacy Policy at any time. Material changes — meaning changes that substantially affect your rights or the way we use your personal data — will be communicated to you by email to the address registered on your Account and by a prominent notice on the Platform at least fourteen (14) days before the changes take effect.

Minor updates, such as corrections of typographical errors or clarifications that do not alter the substance of the Policy, may be made without prior notice. The date at the top of this Policy will always reflect the most recent revision. Your continued use of the Platform following the effective date of any amendment constitutes your acknowledgment and acceptance of the revised Policy.

We recommend reviewing this Policy periodically to remain informed about how pln86 protects your information. If you have questions about any proposed or recent change, please contact our support team before the effective date.

16 Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or the manner in which pln86 processes your personal data, please reach out to us through the following channel:

If you are unsatisfied with our response to your privacy complaint, you have the right to escalate the matter to the Curaçao eGaming licensing authority or to the data protection supervisory authority in your country of residence. pln86 will cooperate fully with any such authority in the investigation of a complaint.

For formal legal notices relating to data protection matters, please mark your correspondence clearly as "Legal Notice – Data Protection" in the email subject line. We will acknowledge receipt of formal notices within two (2) business days.