loby89 Privacy Policy

1. Introduction

loby89 ("loby89", "we", "us", "our") is committed to protecting the privacy and personal data of every individual who visits, registers on, or interacts with the loby89 platform at loby89.cam (the "Platform"). This Privacy Policy ("Policy") describes how loby89 collects, processes, stores, shares, and protects personal information in connection with the online gambling services we provide to members primarily located in Indonesia.

This Policy applies to all current and former loby89 members, to prospective members who have initiated but not completed registration, and to visitors who browse the Platform without registering. It covers all personal data processing activities carried out by loby89 regardless of the device or connection method used.

loby89 operates its services in accordance with internationally recognized data-protection principles, including purpose limitation, data minimization, storage limitation, accuracy, integrity, confidentiality, and accountability. While Indonesia's Law No. 27 of 2022 on Personal Data Protection (UU PDP) establishes the primary legislative framework applicable to Indonesian-resident data subjects, loby89 additionally aligns its practices with the standards articulated in internationally recognized frameworks to ensure a consistent and high level of protection for all members.

2. Data Controller

loby89 is the data controller in respect of all personal data collected through the Platform. As data controller, loby89 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable data-protection law.

All data-related inquiries, access requests, rectification requests, and erasure requests should be directed to our dedicated privacy team at:

3. Personal Data We Collect

3.1 Data You Provide Directly

When you register an account or interact with loby89's services, you provide us with the following categories of personal data:

• Identity data: Full legal name, date of birth, gender, and national identity number (NIK) as stated on your KTP (Kartu Tanda Penduduk) or equivalent government-issued identification document.
• Contact data: Email address, mobile phone number registered in Indonesia, and residential address (including city, province, and postal code).
• Authentication data: Username, hashed password, and security questions. Passwords are stored exclusively as salted one-way hashes; loby89 staff cannot view your plaintext password at any time.
• Financial data: Bank account numbers (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata, BSI), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja), and transaction records including deposit amounts, withdrawal requests, and processing timestamps, all denominated in Indonesian Rupiah (IDR).
• KYC documentation: Copies of government-issued photo identification, proof of address, and, where required for enhanced due diligence, source-of-funds documentation.
• Communication data: Records of your correspondence with loby89's customer support team, including live chat transcripts, email threads, and support ticket histories.

3.2 Data Collected Automatically

When you access the Platform, our systems automatically record certain technical data:

• Device and browser data: IP address, device type, operating system, browser version, screen resolution, and language settings.
• Usage data: Pages visited on the Platform, session duration, game sessions initiated, bets placed, features accessed, and navigation paths.
• Log data: Server access logs, error logs, and security event logs maintained for fraud detection and platform stability purposes.
• Geolocation data: Approximate geographic location derived from your IP address (city and region level only — loby89 does not collect precise GPS-level location data).

3.3 Data from Third Parties

In limited circumstances, loby89 may receive personal data about you from third parties, including:

• Identity verification and KYC service providers used to confirm the authenticity of documents you submit.
• Payment processors and banking partners, who provide transaction confirmation and fraud-screening signals.
• Responsible gaming and self-exclusion registries, where you have registered yourself and consented to that information being shared with licensed operators.

4. How We Use Your Personal Data

loby89 processes your personal data for the following purposes, each of which rests on a defined legal basis:

1. Account creation and management. To register your loby89 account, authenticate your identity at login, manage your account settings, and communicate essential service information to you. Legal basis: performance of a contract.
2. Transaction processing. To process deposits and withdrawals via BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata, BSI, OVO, DANA, GoPay, ShopeePay, and LinkAja; to maintain accurate financial records; and to issue correct tax documentation where required. Legal basis: performance of a contract; compliance with legal obligations.
3. Identity verification and fraud prevention. To verify that you meet loby89's 21+ age requirement and residency criteria, to fulfill our Know Your Customer (KYC) obligations, and to detect, investigate, and prevent fraudulent transactions, money laundering, and unauthorized account access. Legal basis: compliance with legal obligations; legitimate interests.
4. Responsible gaming monitoring. To monitor member activity for indicators of problem gambling, enforce self-exclusion elections, apply deposit and session limits, and comply with our responsible gaming obligations. Legal basis: legitimate interests; compliance with legal obligations.
5. Customer support. To respond to inquiries, resolve disputes, and maintain support ticket records. loby89's Indonesian-speaking support agents operate 24/7, including during Idul Fitri, Ramadhan, and all Indonesian national holidays. Legal basis: performance of a contract; legitimate interests.
6. Platform improvement and security. To analyze usage patterns, diagnose technical issues, enhance product features, and maintain the security and stability of the Platform. Legal basis: legitimate interests.
7. Marketing communications. To send you promotional offers, bonus notifications, and news about loby89 products — but only where you have opted in to receive such communications. You may withdraw your marketing consent at any time by contacting [email protected]. Legal basis: consent.
8. Legal compliance. To comply with applicable Indonesian laws and regulations, respond to lawful requests from regulatory or law-enforcement authorities, and enforce loby89's Terms and Conditions. Legal basis: compliance with legal obligations.

5. Data Sharing and Disclosure

loby89 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share personal data only in the following limited circumstances, and only to the extent strictly necessary:

5.1 Service Providers

loby89 engages carefully vetted third-party service providers who process personal data on our behalf under binding data-processing agreements. These include identity verification and KYC vendors, payment processing partners (including the Indonesian bank and e-wallet networks listed above), cloud infrastructure providers, fraud-detection and cybersecurity firms, game content providers (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Pocket Games Soft, Spribe, and others), and customer support platform operators. All such providers are contractually prohibited from using member data for any purpose beyond the specific service they perform for loby89.

5.2 Legal and Regulatory Disclosures

loby89 may disclose personal data to government authorities, law enforcement agencies, courts, or regulators where required to do so by applicable law, by a lawful court order, or where disclosure is necessary to protect the rights, property, or safety of loby89, its members, or the general public. In all such cases, loby89 will disclose only the minimum personal data necessary to satisfy the legal requirement.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of loby89's assets, member personal data may be transferred to the relevant successor entity. loby89 will provide affected members with reasonable advance notice of any such transfer and will ensure that the successor entity is bound by data-protection obligations no less protective than those set out in this Policy.

5.4 Aggregated and Anonymized Data

loby89 may share aggregated, anonymized, or de-identified data — which cannot reasonably be used to identify any individual — with business partners, researchers, or the public for analytical or product-development purposes. This is not personal data sharing and is not subject to the restrictions in this section.

6. Cookies and Tracking Technologies

loby89 uses cookies and similar client-side tracking technologies (including local storage and session storage) to deliver a functional, personalized, and secure Platform experience. The following categories of cookies are used:

• Strictly necessary cookies: Required for the Platform to function. They maintain your login session, remember your language and currency preferences, and enable the shopping-cart equivalent for pending bets. These cannot be disabled without impairing Platform functionality.
• Analytics cookies: Used to collect anonymized data about how members navigate the Platform, which pages are visited most frequently, and where technical errors occur. This data is used exclusively to improve Platform performance and user experience.
• Security cookies: Used to detect and prevent fraudulent logins, bot traffic, and account-takeover attempts. These cookies analyze device fingerprint and behavioral signals to identify anomalous activity.
• Preference cookies: Store your display preferences such as table layout, notification settings, and responsible gaming limit configurations so they persist between sessions.

loby89 does not use third-party advertising cookies or behavioral retargeting pixels. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies will prevent you from logging in to your loby89 account.

7. Data Security

loby89 implements a multi-layered security architecture designed to protect member personal data against unauthorized access, disclosure, alteration, or destruction. Key security measures include:

• Transport encryption: All data transmitted between your browser or app and the loby89 Platform is encrypted using TLS 1.2 or higher (256-bit SSL). Expired or insecure TLS configurations are rejected automatically.
• Data-at-rest encryption: Sensitive database fields — including identity documents, financial account references, and KYC records — are encrypted at rest using AES-256.
• Password security: Member passwords are stored exclusively as salted bcrypt hashes. loby89 staff have no ability to view plaintext passwords. Passwords that appear in known breach databases are flagged and members are prompted to change them.
• Two-factor authentication (2FA): loby89 supports and strongly encourages the use of 2FA on all member accounts. 2FA can be enabled through your account security settings.
• Access controls: Internal access to member personal data is restricted to personnel with a documented operational need. Access is logged, reviewed regularly, and subject to the principle of least privilege.
• Penetration testing and vulnerability management: loby89 engages independent security researchers to conduct regular penetration tests and vulnerability assessments of the Platform. Critical findings are remediated within defined SLA windows.

8. Exercising Your Data Rights

As a loby89 member and an Indonesian resident, you hold the following rights with respect to your personal data under applicable data-protection law. To exercise any of these rights, submit a written request to [email protected] with the subject line "Privacy Request — [Your Registered Username]". loby89 will acknowledge your request within 3 business days (WIB) and fulfill it within 30 calendar days. In complex cases, the fulfillment period may be extended by a further 30 days, and you will be notified of the extension and the reason for it.

• Access: Receive a copy of the personal data loby89 holds about you, the purposes of processing, the categories of data, and the recipients with whom it has been shared.
• Rectification: Request correction of inaccurate personal data. Where technically possible, you may update your own profile data directly through account settings.
• Erasure ("right to be forgotten"): Request deletion of your personal data. Note that loby89 is required by law to retain certain financial and identity records for a minimum of five years following account closure; erasure requests will be honored to the maximum extent permitted by these legal retention obligations.
• Restriction of processing: Request that loby89 restricts processing of your data while the accuracy of the data is being contested or a legitimate-interests assessment is underway.
• Portability: Receive an export of the data you have provided to loby89 in a structured, machine-readable format (JSON or CSV).
• Objection: Object to processing based on legitimate interests, including profiling for marketing purposes. loby89 will cease such processing unless compelling legitimate grounds that override your interests can be demonstrated.
• Withdraw consent: Where processing is based on your consent (for example, marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

loby89 will not charge a fee for handling data-rights requests unless requests are manifestly unfounded or excessive, in which case a reasonable administrative fee may be applied.

9. Data Retention

loby89 retains personal data for the periods set out in the table below, or for longer where required by applicable law. Following the expiry of the applicable retention period, data is securely deleted or irreversibly anonymized.

10. Minors and Age Protection

The loby89 Platform is strictly intended for individuals aged 21 and over. loby89 does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted as part of the registration process and may be repeated at any time through our KYC procedures.

If loby89 discovers or is notified that personal data has been collected from a person under the age of 21, we will take immediate steps to close the associated account, return any deposited funds, and permanently delete all personal data associated with the minor's registration. If you believe that a minor has registered on the Platform, please contact us immediately at [email protected].

Parents and guardians who are concerned about underage access to online gambling are encouraged to use parental control software and to visit our Responsible Gaming page for additional guidance and self-exclusion resources.

11. Changes to This Privacy Policy

loby89 reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, our data processing practices, or the services we offer. When material changes are made, loby89 will:

• Update the "Version effective" date at the top of this page.
• Post a notice on the Platform's homepage for a minimum of 14 days following the change.
• Send an in-platform notification or email to all registered members whose processing activities are materially affected by the change.

Your continued use of the Platform after the effective date of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any material change, you should discontinue use of the Platform and request account closure.

For non-material changes — such as typographical corrections, clarification of existing provisions, or reformatting — loby89 will update this page without separate notification, though the version date will always reflect the most recent revision.

12. Contact and Complaints

For any questions, concerns, or requests relating to this Privacy Policy or loby89's data processing practices, please contact our Privacy & Data Protection Team:

If you are not satisfied with loby89's response to a privacy complaint, you have the right to escalate your concern to the relevant data protection authority. For Indonesian residents, the competent supervisory authority is the Ministry of Communication and Digital Affairs (Kementerian Komunikasi dan Digital, Kemkomdigi), which oversees enforcement of Law No. 27 of 2022 on Personal Data Protection (UU PDP).

loby89 takes all privacy complaints seriously and will work in good faith to resolve any concern promptly and fairly. We encourage members to contact us directly in the first instance so that we have the opportunity to address the matter before escalation to a regulatory body.