Privacy Policy — How pt86 Protects Your Data

1 Introduction

pt86 ("the Platform", "we", "us", "our") operates the online gaming platform accessible at https://pt86.cam. As an operator serving registered Players primarily based in Indonesia, pt86 is committed to responsible and transparent data handling practices that respect your privacy and comply with internationally recognised data protection principles.

This Privacy Policy ("Policy") sets out the basis on which pt86 collects, processes, stores, and discloses personal data obtained from or about Players and other users who interact with our platform. This Policy applies to all services offered through pt86, including casino games, sports betting, togel (Indonesia's traditional numbers lottery) markets, live dealer games, and all customer support channels.

This Policy should be read together with pt86's Terms & Conditions, which govern your use of the platform. In the event of any inconsistency between the two documents regarding data matters, this Privacy Policy shall prevail.

If you have questions about how pt86 handles your data, you may contact our Data Protection team at any time using the details set out in Section 15 of this Policy.

2 Definitions

Throughout this Privacy Policy, the following terms carry the meanings set out below:

• "Personal Data" — Any information that identifies or could reasonably identify a living individual, including names, identification numbers, location data, online identifiers, or factors specific to the physical, economic, or social identity of that individual.
• "Processing" — Any operation performed on Personal Data, whether automated or manual, including collection, recording, organisation, storage, adaptation, retrieval, use, disclosure, erasure, or destruction.
• "Data Subject" — The identified or identifiable natural person to whom Personal Data relates; in the context of pt86, this is primarily each registered Player.
• "Data Controller" — The entity that determines the purposes and means of Processing Personal Data. pt86 acts as a Data Controller in respect of all Player data processed through the platform.
• "Data Processor" — A third party that processes Personal Data on behalf of pt86, under a contractual arrangement and subject to pt86's instructions.
• "Consent" — A freely given, specific, informed, and unambiguous indication of the Data Subject's agreement to the processing of their Personal Data for a stated purpose.
• "Cookie" — A small text file placed on a user's device by a website, used to store preferences, session data, and analytical information.

3 Data We Collect

pt86 collects Personal Data across several categories, depending on how you interact with the platform. The following table summarises the categories of data collected and their typical sources:

4 How We Collect Your Data

pt86 collects Personal Data through the following channels and mechanisms:

• Direct interactions: Data you provide when registering an Account, completing KYC verification, making deposits or withdrawals, adjusting Account settings, or contacting our support team.
• Automated platform systems: Technical and usage data collected automatically when you access and interact with the platform, including via cookies, server logs, and session analytics tools.
• Payment service providers: Financial data transmitted through deposit and withdrawal transactions processed via Indonesian banks and e-wallet providers.
• Identity verification partners: Information returned by third-party KYC and identity verification services engaged by pt86 to validate the accuracy of information you submit during Account registration.
• Fraud prevention systems: Device fingerprinting, geolocation signals, and behavioural analytics generated by security tools designed to detect and prevent fraudulent activity, duplicate accounts, or prohibited access.
• Game software providers: Gameplay data and session information transmitted by third-party game studios (including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming) whose content is integrated into the pt86 platform.

In all cases, pt86 collects only the minimum data necessary to deliver our services, verify your identity, process transactions, and comply with applicable legal and regulatory obligations.

5 How We Use Your Data

pt86 processes your Personal Data for the following purposes, each aligned to a lawful basis as described in Section 6 of this Policy:

• Account administration: To create and maintain your pt86 Account, authenticate your login sessions, and manage your Account status including suspension, closure, or reactivation.
• Identity verification (KYC): To verify your identity, age (21+ requirement), and residency in accordance with pt86's Terms & Conditions and applicable regulatory obligations. This includes screening against sanction lists and self-exclusion registers.
• Transaction processing: To process deposits and withdrawals via BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, OVO, DANA, GoPay, ShopeePay, LinkAja, and any other supported payment methods; to reconcile your Real Money Balance and Bonus Balance; and to generate transaction receipts.
• Game provision: To deliver casino games, sports betting markets, live dealer experiences, and togel lottery services; to record and settle bets; and to credit winnings to your Account.
• Customer support: To respond to your inquiries via live chat, email, or WhatsApp; to investigate and resolve complaints; and to maintain a record of support interactions for quality assurance purposes.
• Fraud prevention and security: To detect and prevent fraudulent activity, duplicate accounts, bonus abuse, collusion, money laundering, and other prohibited conduct as defined in pt86's Terms & Conditions.
• Responsible gaming enforcement: To implement self-exclusion requests, deposit limits, session time-outs, and other responsible gaming tools; to monitor gameplay patterns for signs of problem gambling; and to intervene where necessary to protect vulnerable Players.
• Marketing and promotions: Where you have provided consent, to send promotional offers, bonus notifications, and platform updates via email, SMS, or in-platform messaging. You may withdraw marketing consent at any time via your Account settings.
• Platform improvement: To analyse usage patterns, session data, and feature engagement for the purpose of improving platform performance, user experience, and service reliability.
• Legal compliance: To comply with Indonesian and international legal obligations, including anti-money laundering (AML) requirements, tax reporting obligations (where applicable), and responses to lawful requests from regulatory or law enforcement authorities.

6 Legal Basis for Processing

Under internationally recognised data protection principles, pt86 must establish a lawful basis for each processing activity. The legal bases on which pt86 relies are as follows:

• Contractual necessity: Processing is necessary to perform pt86's obligations under the Terms & Conditions agreement you entered into when registering your Account. This basis covers Account creation, transaction processing, game provision, and KYC verification.
• Legal obligation: Processing is required to comply with laws and regulations applicable to pt86's operations, including AML/CFT requirements, age verification mandates, and responses to lawful regulatory requests.
• Legitimate interests: pt86 has a legitimate interest in processing certain data to prevent fraud, ensure platform security, enforce Terms & Conditions, and improve service quality, provided this interest does not override your fundamental rights and freedoms.
• Consent: For marketing communications and certain optional data uses (such as behavioural analytics for personalisation), pt86 relies on your freely given consent. You may withdraw consent at any time without affecting other platform services.

Where pt86 processes your data on the basis of legitimate interests, you have the right to object to such processing as described in Section 11 of this Policy.

7 Data Sharing & Disclosure

pt86 does not sell, rent, or trade your Personal Data to third parties for marketing purposes. However, we may share your data with the following categories of recipients under strict confidentiality and data protection obligations:

• Payment processors: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) receive transaction instructions and account identifiers necessary to process deposits and withdrawals.
• Game software providers: Studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive Player identifiers and session tokens required to deliver game content and record gameplay outcomes.
• KYC and verification partners: Third-party identity verification services receive copies of your submitted documents and identity information to validate your age, identity, and residency status.
• Fraud prevention services: Specialised security platforms receive Technical Data (IP addresses, device fingerprints, session metadata) to screen for fraudulent activity, duplicate accounts, and VPN/proxy usage.
• Customer support tools: Cloud-based support platforms (live chat, ticketing systems) process Communications Data to facilitate support interactions and maintain service records.
• Regulatory and legal authorities: pt86 may disclose Personal Data to law enforcement agencies, regulatory bodies, or courts where required by law, court order, or valid regulatory request, including for AML investigations and compliance audits.
• Professional advisers: pt86's legal counsel, auditors, and compliance consultants may access Personal Data under strict confidentiality obligations to provide professional services to the Platform.

All third-party data processors engaged by pt86 are bound by written data processing agreements that require them to implement appropriate technical and organisational security measures and to process data only in accordance with pt86's instructions.

8 Data Retention

pt86 retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or to comply with legal retention obligations, whichever is longer. The following retention periods apply:

• Active Accounts: All Account data, transaction records, and gameplay history are retained for the duration of your active Account status and for seven (7) years following Account closure, in accordance with standard financial record-keeping requirements.
• KYC documentation: Identity documents, selfie photographs, and verification records are retained for a minimum of seven (7) years following Account closure to comply with AML/CFT regulatory obligations.
• Transaction records: Deposit and withdrawal records, including bank and e-wallet transaction logs, are retained for a minimum of seven (7) years to support financial audits and tax reporting obligations.
• Communications records: Support chat transcripts, email correspondence, and complaint records are retained for three (3) years following the date of the last interaction, or longer where disputes remain unresolved.
• Marketing consent records: Records of marketing consent (granted or withdrawn) are retained for the duration of your Account status plus three (3) years to evidence compliance with consent requirements.
• Technical and usage data: Server logs, session data, and analytics records are retained for a maximum of two (2) years, except where required for ongoing fraud investigations.

Upon expiration of the applicable retention period, pt86 securely deletes or anonymises Personal Data using industry-standard data destruction methods. Anonymised data that can no longer identify any individual may be retained indefinitely for statistical and platform improvement purposes.

9 Data Security

pt86 implements technical and organisational security measures designed to protect Personal Data from unauthorised access, disclosure, alteration, and destruction. These measures include but are not limited to:

• Encryption: All data transmitted between your device and pt86's servers is protected by 256-bit SSL/TLS encryption. Sensitive data at rest (including passwords and financial records) is encrypted using industry-standard algorithms.
• Access controls: Personal Data is accessible only to pt86 employees and contractors who require access to perform their job functions. All personnel are bound by confidentiality obligations and receive regular data protection training.
• Network security: pt86's systems are protected by firewalls, intrusion detection systems, and regular vulnerability assessments conducted by independent security specialists.
• Segregated funds: Player funds are held in segregated bank accounts separate from pt86's operational capital, ensuring financial data and balances remain protected even in the event of corporate insolvency.
• Incident response: pt86 maintains a documented data breach response plan. In the event of a security incident affecting Personal Data, pt86 will notify affected Players and relevant authorities in accordance with applicable breach notification requirements.

While pt86 employs robust security measures, no internet-based service can guarantee absolute security. You remain responsible for maintaining the confidentiality of your Account login credentials and for notifying pt86 immediately if you suspect unauthorised Account access.

10 Cookies & Tracking Technologies

pt86 uses cookies and similar tracking technologies to enhance platform functionality, personalise your experience, and analyse usage patterns. A cookie is a small text file stored on your device that enables the platform to recognise your device across sessions.

The following types of cookies are used on pt86:

• Strictly necessary cookies: Required for core platform functions including session management, authentication, and security. These cookies cannot be disabled without impairing platform functionality.
• Performance cookies: Collect anonymous data on how users navigate the platform, which pages are visited, and where errors occur. This data is used to improve site performance and user experience.
• Functionality cookies: Remember your preferences such as language selection, display settings, and game filters, enabling a personalised experience across sessions.
• Analytics cookies: Used by third-party analytics services to measure user engagement, session duration, and feature usage. Data collected is aggregated and anonymised.

You may control or delete cookies through your browser settings. Note that disabling certain cookies may limit your ability to use some platform features. pt86 does not use cookies for third-party advertising tracking.

11 Your Privacy Rights

As a Data Subject, you hold the following rights in respect of your Personal Data processed by pt86. To exercise any of these rights, please contact our Data Protection team using the details in Section 15:

pt86 will respond to all valid rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further sixty (60) days, and you will be notified of any such extension. Requests are processed free of charge unless they are manifestly unfounded or excessive.

12 Minors & Age Protection

pt86 services are available only to individuals aged 21 years or older. pt86 does not knowingly collect Personal Data from minors under the age of 21. All Accounts undergo mandatory age verification during the KYC process, and any Account found to belong to a person under 21 will be immediately closed, with all balances forfeited.

If you believe pt86 has inadvertently collected data from a minor, please contact our support team immediately so that we may investigate and take appropriate action, including data deletion and Account closure.

13 International Data Transfers

pt86 primarily serves Players based in Indonesia. However, certain third-party service providers engaged by pt86 (including game studios, payment processors, and cloud infrastructure providers) may operate servers or data centres located outside Indonesia, including in jurisdictions such as Singapore, Hong Kong, Europe, and the United States.

Where Personal Data is transferred internationally, pt86 ensures that appropriate safeguards are in place, including:

• Standard contractual clauses (SCCs) approved by international data protection authorities
• Processor agreements requiring equivalent data protection standards
• Technical measures including encryption in transit and at rest

By registering on pt86, you acknowledge and consent to the international transfer of your Personal Data as described in this section.

14 Changes to This Privacy Policy

pt86 reserves the right to amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. Where changes are material, pt86 will provide reasonable advance notice to registered Players via email or in-platform notification before the changes take effect.

The "Last Updated" date displayed at the top of this page indicates the date of the most recent revision. Your continued use of pt86 following the effective date of a revised Policy constitutes your acceptance of the updated terms.

We encourage you to review this Policy periodically to stay informed about how pt86 protects your Personal Data.

15 Contact & Data Protection Requests

If you have questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data by pt86, please contact our Data Protection team:

• Email: [email protected] (plain text — not a clickable link)
• Subject line for data requests: "Privacy Rights Request — [Your Account Username]"
• Live Chat: Available 24/7 via the in-platform chat widget (select "Data Protection" as your inquiry category)

To exercise your privacy rights as outlined in Section 11, please submit your request via email with clear identification of the right you wish to exercise. pt86 may request additional identity verification before processing your request to ensure data security.

All formal data protection requests will be acknowledged within three (3) business days and resolved within thirty (30) days as described in Section 11.