Privacy Policy — tkp228

Introduction

tkp228 ("we", "us", "our", "the Platform") is committed to protecting and respecting the privacy of every individual who interacts with our services. This Privacy Policy sets out, in clear and transparent terms, what personal data we collect, why we collect it, how we use it, how long we keep it, and the rights you hold over your information.

We operate as an international online gaming platform serving members primarily based in Indonesia. Our platform offers sports betting, togel (Indonesia's traditional numbers lottery), live casino games, slot titles from certified Game Providers, and crash games — all denominated in Indonesian Rupiah (IDR).

By accessing tkp228.app, registering an account, or using any of our services, you acknowledge that you have read and understood this Privacy 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 immediately.

This policy should be read alongside our Terms & Conditions and our Responsible Gaming page, which together form the full framework governing your use of tkp228.

Data Controller

For the purposes of applicable data protection legislation, tkp228 acts as the data controller in respect of all personal data collected through the Platform. As data controller, tkp228 determines the purposes for which, and the means by which, your personal data is processed.

All data-related enquiries, access requests, and complaints should be directed to our Data Protection contact at:

• Email: [email protected] — please include "Data Protection" in the subject line of your message.
• Response time: We aim to acknowledge all data-related requests within 48 hours (WIB) and to resolve them within 30 calendar days in accordance with internationally recognised data protection standards.

Data We Collect

tkp228 collects personal data in several categories depending on the nature of your interaction with the Platform. The following table summarises the types of data we collect and their primary purpose at the point of collection.

We do not intentionally collect any special categories of sensitive personal data (such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data) unless you voluntarily provide such information in the course of a support interaction or a responsible gaming self-assessment.

How We Collect Data

tkp228 collects personal data through three primary channels:

• Direct interactions: Data you provide when you register an account, make a deposit or withdrawal, submit KYC documents, contact our support team, respond to promotions, or complete a responsible gaming self-assessment.
• Automated technologies: As you browse and use the Platform, we automatically collect Technical Data and Behavioural Data through server logs, cookies, pixel tags, and similar tracking technologies. See Section 11 (Cookies & Tracking) for full details.
• Third parties: We may receive data from identity verification partners who assist with KYC processing, payment processors who facilitate your deposits and withdrawals via Indonesian banks and e-wallets, and fraud-prevention service providers who cross-reference transaction data against known risk signals. We do not purchase personal data from data brokers or social media platforms.

Legal Basis for Processing

tkp228 processes your personal data on one or more of the following lawful bases recognised under internationally applicable data protection standards:

• Contractual necessity: Processing is required to create and maintain your account, process deposits and withdrawals, settle bets, and provide all Platform services as described in our Terms & Conditions.
• Legal obligation: Processing is necessary to comply with applicable anti-money-laundering (AML) requirements, know-your-customer (KYC) obligations, and any lawful instruction from a competent regulatory or law-enforcement authority.
• Legitimate interests: Processing is necessary for tkp228's legitimate interests in operating a secure and commercially viable gaming platform — including fraud detection, responsible gaming monitoring, product development, and service analytics — provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Where we send you marketing communications or deploy non-essential cookies, we do so on the basis of your freely given, specific, and informed consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

Purposes of Processing

tkp228 uses your personal data for the following specific purposes. We do not use your data for any purpose that is incompatible with what is listed here without first obtaining your consent or providing fresh notice.

• Account management: Creating, verifying, and maintaining your member account, including processing login activity, password resets, and profile updates.
• Transaction processing: Facilitating deposits and withdrawals via Indonesian bank transfer (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, OCBC NISP, Bank Permata) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja), and maintaining accurate financial records in IDR.
• Identity verification (KYC): Confirming your identity, age (21+), and residency to comply with our anti-fraud and AML obligations and to protect the integrity of the Platform.
• Fraud prevention and security: Monitoring account activity, betting patterns, and financial transactions to detect and prevent fraud, money laundering, collusion, bot usage, and other Prohibited Conduct as defined in our Terms & Conditions.
• Responsible gaming: Monitoring play behaviour to identify early indicators of problem gambling, enforcing deposit limits and self-exclusion requests, and providing proactive outreach to members who show signs of at-risk play.
• Customer support: Responding to enquiries, resolving disputes, and maintaining a record of communication history to ensure consistent service quality.
• Marketing and promotions: Sending you personalised promotional offers, bonus notifications, and event-based campaigns (such as Idul Fitri or Ramadhan promotions) where you have opted in to receive such communications.
• Platform improvement: Analysing aggregated and anonymised behavioural data to improve game selection, user experience, localisation features, and overall Platform performance.
• Legal compliance: Retaining transaction and identity records as required by applicable financial regulations and responding to lawful requests from competent authorities.

Data Sharing & Disclosure

tkp228 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share your data only in the limited circumstances described below, and only to the extent strictly necessary.

• Game Providers: When you launch a game, limited session data (such as your member ID and wallet balance) is transmitted to the relevant Game Provider — for example, Pragmatic Play, Evolution Gaming, PG Soft, NetEnt, Microgaming, or Spribe — to enable the game to function. Game Providers are prohibited from using this data for any purpose other than game operation and session integrity verification.
• Payment processors: Your financial data is shared with the relevant Indonesian bank or e-wallet operator (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, LinkAja) to the extent necessary to process the specific transaction you have initiated. We do not store full bank account credentials on our servers.
• KYC and identity verification partners: Your identity documents may be processed by a third-party KYC provider acting as our data processor. These partners operate under strict data processing agreements and are not permitted to use your documents for any purpose outside of identity verification for tkp228.
• Fraud prevention services: Aggregated transaction and device data may be shared with specialist fraud-detection providers to assess risk signals. These providers operate as data processors under contractual data protection obligations.
• Legal and regulatory authorities: We will disclose personal data to competent authorities — including law enforcement agencies, financial intelligence units, or courts — where we are legally obliged to do so, or where disclosure is necessary to protect the rights, property, or safety of tkp228, our members, or the public.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of tkp228's business, personal data held by tkp228 may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any change in the identity of the data controller via a prominent notice on the Platform.

International Transfers

As an internationally licensed gaming platform, some of tkp228's infrastructure, Game Providers, and service partners operate outside of Indonesia. Where your personal data is transferred to or processed in a country other than Indonesia, tkp228 takes all reasonably practicable steps to ensure that your data receives a level of protection equivalent to that described in this Privacy Policy.

Such steps include:

• Entering into data processing agreements with all third-party processors that include binding data protection obligations consistent with internationally recognised standards.
• Applying contractual clauses that require overseas recipients to process personal data only for the purposes for which it was shared and to maintain appropriate technical and organisational security measures.
• Conducting periodic assessments of third-party processors to verify continued compliance with our data protection standards.

By using the Platform, you acknowledge that your personal data may be transferred to and processed in countries outside of Indonesia as part of the normal operation of the tkp228 service.

Data Retention

tkp228 retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, taking into account any applicable legal, accounting, or regulatory retention requirements. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be associated with any identifiable individual. Anonymised and aggregated data may be retained indefinitely for analytical and product development purposes.

Security Measures

tkp228 maintains a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, disclosure, alteration, and destruction. These measures include, but are not limited to:

• Encryption in transit: All data transmitted between your device and tkp228 servers is encrypted using TLS 1.2 or higher (256-bit SSL). This applies to account login, deposit and withdrawal flows, KYC document uploads, and all live game communications.
• Encryption at rest: Sensitive data fields — including identity document data, financial account references, and password hashes — are encrypted at rest using industry-standard algorithms. Passwords are stored as salted, one-way cryptographic hashes and are never stored or transmitted in plaintext.
• Access controls: Internal access to member data is governed by a role-based access control (RBAC) system. Staff members are granted access only to the data categories required for their specific operational role. All internal access events are logged and audited.
• Infrastructure security: tkp228's hosting infrastructure is protected by web application firewalls (WAF), intrusion detection systems (IDS), DDoS mitigation, and regular penetration testing by independent security specialists.
• Incident response: tkp228 maintains a documented data breach response procedure. In the event of a security incident that poses a risk to member data, we will notify affected individuals within a timeframe consistent with internationally recognised data protection standards.

Cookies & Tracking Technologies

tkp228 uses cookies and similar tracking technologies to ensure the Platform functions correctly, to remember your preferences, and to analyse how members and visitors use our services. A cookie is a small text file placed on your device by a web server; it does not give us access to your device and cannot carry viruses or malware.

We use the following categories of cookies:

• Strictly necessary cookies: These are essential for the Platform to function. They enable core features such as session authentication, bet slip management, and secure checkout flows for deposits. These cookies cannot be disabled without impairing your ability to use the Platform.
• Functional cookies: These remember your preferences — such as your preferred game lobby view, notification settings, and language display — so you do not have to re-enter them each time you visit.
• Analytical cookies: These collect anonymised and aggregated information about how visitors navigate and use the Platform, which pages are most visited, and where users encounter errors. This data is used exclusively for internal product improvement and is never used to identify individual users.
• Session security cookies: Short-lived cookies used to associate your current browsing session with your authenticated member account, preventing session hijacking and cross-site request forgery (CSRF) attacks.

tkp228 does not use third-party advertising cookies or retargeting pixels. You may manage cookie preferences through your browser settings. Please note that disabling certain categories of cookies may affect the functionality of some Platform features.

Your Data Rights

As a data subject, you hold the following rights in respect of your personal data held by tkp228. To exercise any of these rights, please contact us at [email protected] with the subject line "Data Rights Request".

• Right of access: You may request a copy of all personal data we hold about you, along with information about how it is processed, the legal basis for processing, and the categories of recipients with whom it has been shared.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it without undue delay.
• Right to erasure: You may request that we delete your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where processing is unlawful. This right is subject to our legal retention obligations — we may be required to retain certain data (e.g., transaction records) for a defined period even after account closure.
• Right to restriction: You may request that we restrict the processing of your personal data in certain circumstances — for example, while the accuracy of data you have contested is verified.
• Right to data portability: Where processing is based on your consent or on contractual necessity and is carried out by automated means, you may request that we provide your personal data in a structured, commonly used, machine-readable format.
• Right to object: You have the right to object to processing of your personal data for direct marketing purposes at any time. You may also object to processing carried out on the basis of legitimate interests where you believe your rights and freedoms override those interests.
• Right to withdraw consent: Where processing is based on your consent (e.g., for marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

We will respond to all data rights requests within 30 calendar days. In complex cases, we may extend this period by a further 60 days, in which case we will notify you of the extension and the reason for it within the initial 30-day window.

Minors & Age Verification

tkp228 is strictly an adults-only platform. You must be at least 21 years of age to register an account or use any tkp228 service. We do not knowingly collect personal data from individuals under the age of 21.

Age verification is a mandatory step in our KYC process. Where there is any doubt about a member's age, we will request a government-issued identity document (KTP or passport) before permitting continued access to paid gaming features. If we discover that personal data has been collected from a person under 21, we will immediately suspend the associated account, delete all collected data, and return any deposited funds to the source payment method subject to identity verification.

If you are a parent or guardian and believe that a minor in your care has registered a tkp228 account, please contact us immediately at [email protected] and we will investigate and take appropriate action without delay.

Changes to This Policy

tkp228 may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or the structure of our Platform. When we make material changes — meaning changes that significantly affect how we collect, use, or share your personal data — we will notify active members via a prominent notice on the Platform and, where practicable, by direct communication to your registered contact details.

The "Last Updated" date at the top of this page will be revised whenever any amendment, however minor, is made to this policy. We encourage you to review this page periodically to stay informed about how tkp228 protects your personal data.

Your continued use of the Platform following the publication of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with any changes, you must stop using the Platform and may request account closure by contacting our support team.

Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way tkp228 handles your personal data, please reach out to us through any of the following channels. We take all privacy-related enquiries seriously and are committed to resolving them promptly.

• Live Chat: Available 24 hours a day, 7 days a week via the support widget on the Platform. Native Indonesian-speaking agents are on hand at all times to assist members across Jakarta, Surabaya, Medan, Bandung, Bali, and beyond.
• Email: [email protected] — please use the subject line "Privacy Policy Enquiry" or "Data Rights Request" to ensure your message is routed to the correct team. We aim to respond to all email enquiries within 24 hours (WIB).
• Escalation: If you are not satisfied with our initial response to a data-related complaint, you have the right to escalate the matter to a competent supervisory authority or seek resolution through an independent dispute mechanism. Our support team can advise you on available escalation routes upon request.