Privacy Policy — ceri89

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

• "ceri89", "we", "us", "our" — refers to the operator of the ceri89 platform at https://ceri89.cam.
• "Platform" — the ceri89 website, mobile interface, APIs, and all associated sub-domains and services.
• "Member", "you", "your" — any individual who has registered an account on the Platform or who browses the Platform without having registered.
• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, email address, date of birth, Indonesian national identity card number (KTP), payment account details, IP address, and device identifiers.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, transfer, deletion, and anonymization.
• "KYC" — Know Your Customer; the identity verification process required before withdrawals are processed.
• "Third-Party Processor" — any external organization that processes Personal Data on behalf of ceri89 under a data processing agreement, including payment processors, KYC verification providers, and fraud prevention services.

2.1  ceri89 acts as the data controller in respect of all Personal Data collected through the Platform. As data controller, ceri89 determines the purposes and means by which your Personal Data is processed.

2.2  Where ceri89 engages Third-Party Processors — such as payment gateway operators, KYC verification providers, or fraud detection services — those parties act as data processors under documented data processing agreements that obligate them to process your Personal Data solely on ceri89's instructions, maintain appropriate security measures, and not use your data for their own independent purposes.

2.3  Contact details for data-related enquiries are set out in Section 15 of this Policy.

3.1  ceri89 collects the following categories of Personal Data:

3.2  ceri89 does not collect or store full payment card numbers, CVV codes, or any other payment card security credentials. Where card payments are supported, all card data is handled directly by our PCI-DSS-certified payment gateway partners and is never transmitted to or stored on ceri89 servers.

3.3  ceri89 does not knowingly collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data (except where a Member voluntarily discloses a gambling-related health concern through the responsible gaming tools), or criminal conviction records beyond what is strictly required for fraud and AML compliance obligations.

4.1  Directly from you: The majority of your Personal Data is collected directly when you register an account, complete KYC verification, make a deposit or withdrawal request, contact our support team, or interact with platform features such as responsible gaming tools or promotional opt-ins.

4.2  Automatically: When you access the Platform, ceri89's servers and analytics tools automatically collect Technical Data and Usage Data through server logs, session tracking, and cookies or similar technologies. See Section 11 for the full cookies policy.

4.3  From Third-Party Processors: ceri89 may receive data from its KYC verification and fraud-screening partners in the course of verifying your identity or assessing transaction risk. This data is used solely for the purposes for which it was shared and is not combined with data obtained for unrelated purposes.

5.1  ceri89 processes your Personal Data on one or more of the following legal bases, depending on the specific data and purpose:

• Contractual Necessity: Processing your identity, contact, and financial data is necessary to enter into and perform the Member agreement (the Terms & Conditions), including registering your account, processing deposits and withdrawals, and resolving disputes.
• Legal Obligation: ceri89 is required by its international gaming licence and associated anti-money laundering (AML) and Know Your Customer (KYC) obligations to collect and retain certain categories of Personal Data for defined minimum periods.
• Legitimate Interests: ceri89 processes Technical Data and Usage Data on the basis of its legitimate interest in maintaining platform security, preventing fraud, monitoring for responsible gaming concerns, and improving the Member experience — provided these interests are not overridden by your own rights and interests.
• Consent: Where ceri89 sends you direct marketing communications or sets non-essential cookies, it does so only on the basis of your prior, freely given, specific, and informed consent. You may withdraw this consent at any time by contacting support.

6.1  ceri89 uses the Personal Data it collects for the following purposes:

1. Account Management: To create, maintain, and secure your ceri89 account, including processing login requests, enforcing the one-account-per-person rule, and managing account closures or self-exclusions requested under the Responsible Gaming policy.
2. Transaction Processing: To process deposits and withdrawals via BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, LinkAja, and other accepted Indonesian payment channels, and to maintain accurate financial records.
3. Identity Verification (KYC): To verify that you are who you claim to be, that you meet the 21+ age requirement, and that withdrawal requests are directed to payment accounts registered in your own name.
4. Fraud and AML Prevention: To detect, investigate, and prevent fraudulent activity, money laundering, bonus abuse, collusion, and other prohibited conduct as defined in the Terms & Conditions.
5. Responsible Gaming: To monitor betting patterns that may indicate problem gambling behavior and to action self-exclusion or deposit limit requests promptly in accordance with the Responsible Gaming framework.
6. Customer Support: To respond to your enquiries, process complaints, and maintain records of support interactions for quality assurance and legal compliance purposes.
7. Platform Improvement: To analyze Usage Data and Technical Data in aggregate to understand how Members use the Platform and to improve its design, performance, and feature set.
8. Legal Compliance: To fulfil ceri89's obligations under its international gaming licence, applicable data protection frameworks, and any lawful request from a competent regulatory authority.
9. Marketing Communications: To send you promotional offers, bonus notifications, and platform news where you have consented to receive such communications. You may opt out at any time.

7.1  ceri89 may share your Personal Data with the following categories of third parties, strictly as necessary and under appropriate contractual safeguards:

• Payment Processors: Local Indonesian bank transfer operators and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) receive only the transaction data necessary to initiate or confirm a specific deposit or withdrawal.
• KYC and Identity Verification Providers: Third-party KYC specialists receive copies of your identity documents and, where applicable, facial biometric data solely to verify your identity. These providers are contractually prohibited from retaining or using your data beyond the verification purpose.
• Fraud Prevention and AML Services: Specialized fraud screening partners may receive transaction data and device identifiers to assess risk. All such partners operate under strict data processing agreements.
• Game Content Providers: Game studios such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Pocket Games Soft receive a pseudonymous player identifier (not your real name or contact details) necessary to deliver game sessions and maintain game-level records.
• Regulatory and Legal Authorities: ceri89 will disclose Personal Data to competent regulatory bodies, law enforcement agencies, or courts where required to do so by a lawful order or to protect the rights, property, or safety of ceri89, its Members, or the public.
• Business Successors: In the event of a merger, acquisition, or sale of all or substantially all of ceri89's assets, your Personal Data may be transferred to the acquiring entity, subject to the same privacy protections as set out in this Policy. Members will be notified of any such transfer via the registered email address.

7.2  ceri89 does not transfer your Personal Data to jurisdictions that do not maintain an adequate level of data protection without first implementing appropriate safeguards, such as standard contractual clauses.

8.1  ceri89 implements a layered set of technical and organizational security measures to protect your Personal Data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Transport Layer Security: All data in transit between your device and ceri89's servers is encrypted using TLS 1.2 or higher (256-bit SSL).
• Data-at-Rest Encryption: Sensitive Personal Data stored in ceri89's databases — including KYC document data and financial data — is encrypted at rest using AES-256 encryption.
• Access Controls: Internal access to Member Personal Data is governed by role-based access controls (RBAC). Staff access is logged, audited, and subject to regular review. No staff member has unrestricted access to the full Member data set.
• Password Security: Member account passwords are stored as salted cryptographic hashes. ceri89 staff cannot retrieve your password in plain text under any circumstances.
• Intrusion Detection: ceri89's infrastructure is monitored continuously for unauthorized access attempts, DDoS events, and anomalous traffic patterns.
• Vendor Security Assessments: Third-Party Processors that handle Member Personal Data are subject to security due diligence assessments prior to engagement and on an ongoing basis.

8.2  In the event of a data breach that is likely to result in a high risk to the rights and freedoms of Members, ceri89 will notify affected Members at the registered email address without undue delay, providing details of the nature of the breach, the data affected, and the steps ceri89 has taken and recommends you take in response.

8.3  Despite these measures, no online platform can guarantee absolute security. You are also responsible for maintaining the security of your own account credentials and for notifying ceri89 immediately if you suspect unauthorized access to your account.

9.1  ceri89 retains Personal Data only for as long as is necessary to fulfil the purpose for which it was collected, subject to longer retention periods where required by legal, regulatory, or licensing obligations. The general retention framework is as follows:

9.2  When the applicable retention period expires, Personal Data is securely deleted or irreversibly anonymized so that it can no longer be linked to any identifiable individual. Anonymized aggregate data may be retained indefinitely for statistical and analytical purposes.

10.1  As a Member of ceri89, you have the following rights in relation to your Personal Data. To exercise any of these rights, please contact us using the details in Section 15. We will respond within 30 calendar days of receiving your verified request.

10.2  ceri89 will not charge a fee for handling data rights requests that are reasonable in scope. Where a request is manifestly unfounded or excessive, ceri89 reserves the right to charge a reasonable administrative fee or to refuse the request, providing written reasons for doing so.

11.1  ceri89 uses cookies and similar tracking technologies — including local storage objects and session identifiers — to operate and improve the Platform. Cookies are small text files placed on your device by your browser when you visit a website.

11.2  The cookies used on ceri89 fall into the following categories:

• Strictly Necessary Cookies: These are essential for the Platform to function. They enable you to stay logged in, maintain your session state, and navigate the Platform securely. These cookies cannot be disabled without breaking core platform functionality.
• Functional Cookies: These remember your preferences — such as language settings, display options, and responsible gaming tool configurations — to provide a more personalized experience across sessions.
• Analytics Cookies: These collect aggregated, anonymized information about how Members use the Platform — such as which pages are visited most frequently and where users exit the site — to help ceri89 improve its design and content. These are set only with your consent.
• Security Cookies: These are used for fraud detection and bot prevention, including device fingerprinting used to detect duplicate account registrations and automated access attempts.

11.3  You can control non-essential cookies through your browser settings. Most browsers allow you to refuse all cookies or to accept only specific categories. Please note that disabling certain cookies may affect the functionality of parts of the Platform.

11.4  ceri89 does not use third-party advertising or retargeting cookies. No behavioral advertising tracking is deployed on the Platform.

12.1  ceri89 employs age verification measures — including KYC document checks — to prevent underage registration. If ceri89 discovers that Personal Data has been collected from a person under 21, it will immediately suspend the associated account, delete or anonymize all Personal Data collected from that individual, and void any bets placed and any balance held in the account.

12.2  If you are the parent or legal guardian of a person under 21 who you believe has registered an account on ceri89, please contact our support team immediately using the contact details in Section 15 so that appropriate action can be taken without delay.

13.1  The ceri89 Platform does not include links to external third-party websites as part of its standard navigation. Where third-party game content is embedded within the Platform — such as games hosted by Pragmatic Play, Evolution Gaming, or other licensed studios — those games are delivered within an isolated environment and the game studio's own privacy policy applies to data processed by the studio within the game session.

13.2  ceri89 is not responsible for the privacy practices or content of any third-party system that a Member accesses independently of the Platform. We encourage Members to review the privacy policies of any third-party service they use.

14.1  ceri89 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable legal requirements, or platform features. The "Last updated" date at the top of this Policy will be revised accordingly.

14.2  Where a change is material — meaning it significantly affects how your Personal Data is processed or reduces your privacy rights — ceri89 will notify you via the email address registered to your account at least seven (7) days before the change takes effect. For minor clarifications and non-material updates, the revised Policy will be posted on this page without individual notification.

14.3  Continued use of the Platform after the effective date of any amendment constitutes your acceptance of the updated Privacy Policy. If you do not agree to the amended Policy, you may request account closure in accordance with Clause 11.1 of the Terms & Conditions prior to the effective date.

15.1  For any questions, concerns, or requests relating to this Privacy Policy or to your Personal Data held by ceri89, please contact our Data Privacy team:

15.2  ceri89 commits to acknowledging all privacy-related enquiries within 72 hours and to providing a substantive response within 30 calendar days of receiving a verified request. Where a request is complex or numerous, this period may be extended by a further 30 days, in which case we will notify you of the extension and the reasons for it.

15.3  If you are not satisfied with ceri89's response to a privacy concern, you have the right to escalate your complaint to the independent dispute resolution body specified under ceri89's international gaming licence, details of which are available upon request.