Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal information collected by afc88 through our website (https://afc88.cam), mobile applications, customer support channels, and any other platforms or services we operate. This policy governs data collected from users located in Indonesia who access our online sports betting, live casino, and gaming services. afc88 operates as a data controller responsible for determining how your personal information is processed and protected.

We are committed to compliance with applicable data protection laws and regulations, including Indonesian privacy legislation and international standards for cross-border data transfers. Our privacy practices align with principles of transparency, data minimization, purpose limitation, accuracy, storage limitation, integrity, and confidentiality as recognized by global data protection frameworks.

2. Information We Collect

2.1 Information You Provide Directly

When you register an account with afc88, we collect personal information that you voluntarily provide, including:

• Identity Information: Full legal name as it appears on your government-issued identification document, date of birth, gender, nationality, and government-issued ID number (Indonesian KTP number, passport number, or driver's license number).
• Contact Information: Email address, mobile phone number (with Indonesian country code +62), residential address including street, city, province, and postal code.
• Account Credentials: Username, password (stored in encrypted hash format, not plain text), and security questions/answers for account recovery purposes.
• Financial Information: Bank account details (bank name, account holder name, account number) for Indonesian banks including BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, BSI; e-wallet account information for OVO, DANA, GoPay, ShopeePay, LinkAja; credit/debit card details (card number, expiration date, CVV - processed through secure payment gateways and not stored on our servers).
• Verification Documents: Copies of government-issued photo identification (KTP, passport, driver's license), proof of address documents (utility bills, bank statements), selfie photographs holding identification documents, and bank account verification screenshots.
• Communication Data: Content of messages sent through our customer support channels including live chat transcripts, email correspondence, WhatsApp messages, and phone call recordings (with your consent).

2.2 Information Collected Automatically

When you access and use afc88 services, we automatically collect certain technical and usage information through cookies, log files, and similar tracking technologies:

• Device Information: Device type (desktop, mobile, tablet), operating system and version (Windows, macOS, iOS, Android), browser type and version (Chrome, Firefox, Safari, Edge), screen resolution, device identifiers (IMEI, advertising ID), and language settings.
• Connection Data: IP address, internet service provider (ISP), geographic location (country, region, city) derived from IP address, time zone setting (typically WIB for Indonesian users), and network connection type (WiFi, cellular 4G/5G).
• Usage Data: Pages visited, features used, time spent on each page, clickstream data (sequence of pages/features accessed), login timestamps, bet placement history, game play records, deposit and withdrawal transactions, bonus claims, and interaction patterns.
• Performance Data: Platform performance metrics, error logs, crash reports, load times, and technical diagnostics used to improve service reliability and user experience.

2.3 Information from Third-Party Sources

We may receive information about you from third-party sources including payment processors (transaction verification data), identity verification services (document authentication results, fraud risk assessments), gaming software providers (game play data, win/loss records), and public databases (verification of information you provide).

3. How We Use Your Information

afc88 processes your personal information for the following legitimate purposes:

3.1 Account Management and Service Delivery

• Creating and maintaining your user account
• Processing deposits, withdrawals, and financial transactions in Indonesian Rupiah (IDR)
• Enabling you to place bets on sports events, play casino games, and access all platform features
• Calculating odds, determining bet outcomes, and crediting winnings to your account
• Processing bonus claims and tracking wagering requirement progress
• Providing customer support and responding to inquiries via live chat, email, and WhatsApp
• Sending transactional notifications regarding account activity, deposits, withdrawals, and important service updates

3.2 Verification and Compliance

• Verifying your identity, age (21+ requirement), and residency status in Indonesia
• Conducting Know Your Customer (KYC) and Anti-Money Laundering (AML) checks as required by law
• Detecting and preventing fraud, money laundering, terrorist financing, and other illegal activities
• Identifying duplicate accounts and enforcing our one-account-per-person policy
• Investigating suspicious betting patterns, collusion, bonus abuse, and Terms violations
• Complying with legal obligations, regulatory requirements, and law enforcement requests
• Maintaining transaction records for audit and compliance purposes

3.3 Platform Improvement and Analytics

• Analyzing user behavior and preferences to improve platform features and user experience
• Conducting market research to understand Indonesian player preferences for sports betting, casino games, and payment methods
• Testing new features, games, and promotional offers
• Optimizing platform performance, load times, and mobile responsiveness
• Developing new products and services tailored to Indonesian market needs

3.4 Marketing and Communication (with Consent)

• Sending promotional emails about new bonuses, special offers, and platform updates (you may opt-out at any time)
• Providing personalized bonus offers based on your betting activity and preferences
• Notifying you about sports events relevant to your betting history (BRI Liga 1, EPL, Champions League, etc.)
• Conducting customer satisfaction surveys and feedback collection

3.5 Security and Protection

• Protecting against unauthorized account access through multi-factor authentication and login monitoring
• Detecting and preventing cyber attacks, hacking attempts, and data breaches
• Implementing responsible gaming measures including deposit limits, self-exclusion, and problem gambling detection
• Enforcing our Terms & Conditions and investigating violations

4. Legal Basis for Processing

Under applicable data protection laws, we process your personal information based on the following legal grounds:

• Contractual Necessity: Processing is necessary to fulfill our contractual obligations under the Terms & Conditions you agreed to when creating your account. This includes account management, payment processing, and service delivery.
• Legal Obligation: Processing is required to comply with legal and regulatory requirements including KYC/AML laws, age verification mandates, tax reporting obligations, and law enforcement requests.
• Legitimate Interests: Processing serves our legitimate business interests in preventing fraud, improving services, maintaining platform security, and conducting business analytics, provided these interests are not overridden by your privacy rights.
• Consent: For marketing communications, optional data collection, and non-essential cookies, we obtain your explicit consent which you may withdraw at any time.

5. How We Protect Your Information

afc88 implements comprehensive technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

5.1 Technical Security Measures

• Encryption: All data transmission between your device and our servers is protected by 256-bit SSL/TLS encryption. Sensitive data at rest (stored data) is encrypted using AES-256 encryption.
• Secure Authentication: Passwords are hashed using industry-standard bcrypt algorithm and never stored in plain text. Multi-factor authentication (MFA) is available for enhanced account security.
• Firewall Protection: Network-level firewalls and intrusion detection systems (IDS) monitor and block malicious traffic.
• Data Segregation: Sensitive financial data and personal information are stored in separate, access-controlled databases with strict permission hierarchies.
• Regular Security Audits: Third-party security firms conduct penetration testing and vulnerability assessments on a quarterly basis.
• Secure Payment Processing: Credit card data is processed through PCI-DSS compliant payment gateways and never stored on afc88 servers.

5.2 Organizational Security Measures

• Access Controls: Personal data access is restricted to authorized personnel who require it for their job functions. All access is logged and monitored.
• Employee Training: Staff undergo regular data protection and security awareness training.
• Confidentiality Agreements: All employees and contractors sign strict confidentiality agreements.
• Vendor Management: Third-party service providers handling personal data must meet our security standards and sign data processing agreements.
• Incident Response Plan: We maintain a documented data breach response plan to quickly identify, contain, and remediate security incidents.

6. Data Sharing and Disclosure

afc88 does not sell, rent, or trade your personal information to third parties for marketing purposes. We may share your information only in the following limited circumstances:

6.1 Service Providers

We share data with trusted third-party service providers who perform services on our behalf, including payment processors (for processing deposits/withdrawals via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay), identity verification services (for KYC/AML compliance), gaming software providers (for delivering slot games and live casino experiences), cloud hosting providers (for data storage and platform infrastructure), and customer support tools (for live chat and ticketing systems). These providers are contractually bound to process data only as instructed by afc88 and to maintain appropriate security measures.

6.2 Legal and Regulatory Authorities

We may disclose personal information to law enforcement agencies, regulatory bodies, courts, or government authorities when required by law, legal process, court order, or subpoena, or when necessary to investigate fraud, enforce our Terms & Conditions, protect our legal rights, or comply with AML/CTF reporting obligations.

6.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the successor entity. You will be notified of any such change via email and will have the opportunity to delete your account before the transfer.

6.4 With Your Consent

We may share information with third parties when you explicitly consent to such sharing, such as participating in partner promotions or surveys.

7. International Data Transfers

While afc88 primarily serves Indonesian users, some of our service providers and data storage facilities may be located outside Indonesia. When we transfer personal information internationally, we ensure that:

• The recipient country provides an adequate level of data protection as recognized by applicable law, or
• We implement appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by data protection authorities, or
• We obtain your explicit consent for the transfer after informing you of the risks.

All international data transfers are encrypted during transmission and stored securely at the destination.

8. Data Retention

afc88 retains your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy and to comply with legal obligations:

• Active Accounts: Personal data is retained for the duration of your active account plus an additional period required by law.
• Closed Accounts: After account closure, we retain identity verification documents, transaction records, and bet histories for seven (7) years to comply with AML regulations, tax laws, and potential dispute resolution.
• Marketing Data: If you opt out of marketing communications, we retain your email address/phone number on a suppression list to ensure we do not contact you again.
• Support Communications: Customer service records are retained for three (3) years for quality assurance and dispute resolution purposes.

After the retention period expires, personal data is securely deleted or anonymized such that it can no longer identify you.

9. Your Privacy Rights

Under applicable data protection laws, you have the following rights regarding your personal information:

• Right of Access: You may request a copy of all personal data we hold about you. We will provide this within 30 days in a structured, commonly used format.
• Right to Rectification: If any personal information we hold is inaccurate or incomplete, you can request that we correct or update it. You can modify many details directly in your account settings.
• Right to Erasure: You may request deletion of your personal data ("right to be forgotten") in certain circumstances, such as when data is no longer necessary for the purposes collected or if you withdraw consent. Note that legal retention obligations may prevent immediate deletion.
• Right to Restriction: You can request that we restrict processing of your personal data in specific situations, such as while disputing data accuracy or contesting the lawfulness of processing.
• Right to Data Portability: You can request that we transfer your data to another service provider in a machine-readable format where technically feasible.
• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes. We will cease processing unless we have compelling legitimate grounds.
• Right to Withdraw Consent: Where processing is based on consent, you can withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to Lodge a Complaint: You have the right to file a complaint with the relevant data protection authority if you believe your privacy rights have been violated.

To exercise any of these rights, contact our Data Protection Officer via email at [email protected] or through our customer support channels. We will respond to requests within 30 days and may require identity verification before processing.

10. Cookies and Tracking Technologies

afc88 uses cookies, web beacons, and similar technologies to enhance user experience, analyze platform usage, and deliver personalized content. Cookies are small text files stored on your device that allow us to recognize you on subsequent visits. We use:

• Essential Cookies: Required for platform functionality including login sessions, account security, and payment processing. These cannot be disabled.
• Performance Cookies: Collect anonymous usage statistics to help us understand how users interact with the platform and identify areas for improvement.
• Functionality Cookies: Remember your preferences such as language settings, time zone, and display options.
• Marketing Cookies: Track your activity across sessions to deliver personalized bonus offers and promotional content (requires consent).

You can manage cookie preferences through your browser settings. Disabling non-essential cookies may limit platform functionality. For detailed cookie information, see our Cookie Policy available via customer support.

11. Children's Privacy

afc88 services are strictly restricted to individuals aged 21 years and older. We do not knowingly collect personal information from anyone under the age of 21. If we discover that we have inadvertently collected data from a minor, we will immediately delete that information and close the associated account. Parents or guardians who believe their child has provided information to afc88 should contact us immediately at [email protected].

12. Third-Party Links

Our platform may contain links to third-party websites, payment providers, or gaming platforms. This Privacy Policy applies only to afc88 services. We are not responsible for the privacy practices of external sites and encourage you to review their privacy policies before providing any personal information.

13. Changes to This Privacy Policy

afc88 reserves the right to modify this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or business operations. Material changes will be communicated via email to your registered address and through prominent notice on our platform. The "Last Updated" date at the top of this policy indicates when the most recent changes were made. Your continued use of afc88 services after policy updates constitutes acceptance of the revised terms. We encourage you to review this policy periodically.

14. Contact Information

For any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact:

• Data Protection Officer: [email protected] (email displayed as plain text for your reference)
• Customer Support: Available 24/7 via live chat on all platform pages
• Email: [email protected] (general inquiries)
• WhatsApp: +62 812-3456-7890 (number displayed as plain text for your reference)
• Response Time: We aim to respond to privacy inquiries within 48 hours during business hours (08:00-22:00 WIB)