h789 Privacy Policy

1. Introduction

h789 ("the Company", "we", "us", "our") operates an online gaming platform designed primarily for players in Indonesia and other markets where international gaming is accessible. We are committed to protecting the personal data of our players and operating in a transparent, accountable manner. This Privacy Policy ("Policy") sets out the legal framework and operational practices that govern our handling of your personal information.

We process personal data for the purposes of providing gaming services, complying with our legal and regulatory obligations, preventing fraud and money laundering, and improving the overall player experience. We do not sell your personal data to third parties for marketing purposes, and we never share your data beyond what is strictly necessary to deliver our services or meet legal obligations.

This Policy should be read alongside our Terms & Conditions and our Responsible Gaming Policy, both of which reference data-related processes that are elaborated upon here.

2. Definitions

• "Personal Data" means any information relating to an identified or identifiable natural person ("data subject"), including name, identification number, location data, and any online identifier that can be used directly or indirectly to identify that person.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, erasure, or any combination thereof.
• "Controller" means h789, the entity that determines the purposes and means of processing Personal Data.
• "Processor" means a third-party entity that processes Personal Data on behalf of h789 under a data processing agreement.
• "Consent" means a freely given, specific, informed, and unambiguous indication of the data subject's agreement to the processing of their Personal Data.
• "KYC" (Know Your Customer) means the identity verification process required by h789 to confirm the identity of Players and comply with anti-money-laundering obligations.
• "Cookies" means small text files stored on your device by a web browser that record your interactions with the Platform.

3. Data We Collect

h789 collects the following categories of Personal Data. The specific data items collected depend on the nature of your interaction with the Platform:

Category	Examples	Purpose
Identity Data	Full legal name, date of birth, KTP/passport number, selfie photograph	Account registration, KYC verification, age verification (21+)
Address Data	Residential address, city (e.g., Jakarta, Surabaya, Bandung, Medan), province, postal code	Identity verification, fraud prevention, jurisdictional compliance
Contact Data	Email address, Indonesian mobile number (WhatsApp-capable)	Account communication, 2FA authentication, support correspondence
Financial Data	Bank account name and number (BCA, BRI, BNI, Mandiri, etc.), e-wallet ID (OVO, DANA, GoPay, ShopeePay, LinkAja), transaction history	Processing deposits and withdrawals, fraud detection, AML compliance
Gaming Activity	Bet history, game sessions, win/loss records, bonus usage, responsible gaming tool interactions	Service delivery, responsible gaming monitoring, dispute resolution
Technical Data	IP address, device type, operating system, browser type, session timestamps	Security monitoring, fraud detection, platform optimization
Usage Data	Pages visited, features used, time on platform, referral source	Product improvement, user experience optimization, analytics
Communications	Live chat transcripts, email correspondence, support tickets	Customer service delivery, quality assurance, dispute evidence

4. How We Collect Your Data

h789 collects Personal Data through the following channels:

• Direct interactions: Data you voluntarily provide when registering an account, completing KYC verification, making deposits or withdrawal requests, contacting customer support, or responding to surveys and promotions.
• Automated technologies: Technical and Usage Data collected automatically when you access the Platform via cookies, server logs, pixel tags, and similar tracking technologies. This data is captured regardless of whether you are logged in to your account.
• Third-party payment providers: Financial Data received from payment processors and Indonesian banking institutions (including BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, OVO, DANA, GoPay, ShopeePay, and LinkAja) when you initiate deposit or withdrawal transactions.
• Identity verification partners: Data received from third-party KYC service providers used to authenticate your identity documents and cross-reference against relevant databases.
• Fraud and security partners: Risk signals and device-fingerprint data received from fraud-prevention services that help us identify suspicious account activity.
• Publicly available sources: In limited circumstances, data sourced from public records or social media profiles where required for fraud investigation or AML compliance purposes.

5. Legal Basis for Processing

h789 processes your Personal Data only where a valid legal basis exists. The applicable legal bases are:

• Contractual necessity: Processing required to deliver the services you have requested — including account management, bet placement, deposits, and withdrawals — is necessary for the performance of our contract with you.
• Legal obligation: Certain processing activities — including KYC verification, anti-money-laundering record keeping, and age verification — are required by applicable law and regulation.
• Legitimate interests: Processing carried out for fraud prevention, platform security, responsible gaming monitoring, and general business analytics, provided such interests are not overridden by your fundamental rights and freedoms.
• Consent: Where we rely on your consent for specific processing activities (such as sending marketing communications), you may withdraw that consent at any time by contacting us at [email protected] or updating your Account notification preferences. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

6. How We Use Your Data

h789 uses the Personal Data we collect for the following specific purposes:

6.1 Service Delivery

To create and maintain your player account, process deposits and withdrawals through your nominated Indonesian bank or e-wallet, settle bets on sports markets (including BRI Liga 1 football, EPL, La Liga, and esports), administer lottery products such as togel (Indonesia's traditional numbers lottery), and deliver the full suite of casino games available on the Platform.

6.2 Identity Verification & Regulatory Compliance

To verify that you are at least 21 years of age, to confirm your identity through KYC checks, and to comply with anti-money-laundering (AML) and counter-terrorism financing (CTF) obligations that apply to international gaming operators. Records maintained for compliance purposes may be retained for up to seven (7) years from account closure.

6.3 Fraud Prevention & Security

To detect, investigate, and prevent fraudulent transactions, bonus abuse, multiple-account creation, unauthorized access, and any other activity that violates our Terms & Conditions. This includes automated monitoring of betting patterns, IP addresses, and device fingerprints.

6.4 Responsible Gaming

To monitor gaming behavior for indicators of problem gambling, to enforce deposit limits, session restrictions, and self-exclusion requests you have activated, and to contact you proactively if our systems identify patterns consistent with harmful play. Data used for responsible gaming purposes is handled with the highest level of confidentiality.

6.5 Customer Support

To respond to your inquiries, resolve disputes, and maintain records of support interactions for quality assurance and training purposes. Our support team operates 24 hours a day, 7 days a week, with Indonesian-speaking agents available at all times.

6.6 Platform Improvement & Analytics

To analyze aggregated and anonymized usage data to improve the functionality, performance, and user experience of the h789 Platform. Analytics data does not identify you personally and is never shared externally in identifiable form.

6.7 Marketing Communications

With your explicit consent, to send you promotional offers, bonus announcements, tournament invitations, and seasonal campaign information relevant to Indonesian players — including campaigns timed around Idul Fitri, Ramadhan, and Indonesian Independence Day. You may opt out of marketing communications at any time through your Account settings or by contacting support.

7. Data Sharing & Disclosure

h789 does not sell, rent, or trade your Personal Data. We disclose data only under the following limited circumstances:

7.1 Service Providers (Processors)

We share data with carefully vetted third-party processors who assist us in delivering our services, including payment gateway operators, KYC/identity verification providers, cloud infrastructure providers, fraud-detection partners, and customer support software vendors. All processors are bound by data processing agreements that restrict their use of your data to the purposes for which it was shared.

7.2 Game Content Providers

Game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive anonymized or pseudonymized game-session data necessary to operate their game software on our Platform. These providers do not receive your identity, financial, or contact data.

7.3 Legal & Regulatory Authorities

We may disclose your Personal Data to law enforcement agencies, regulatory bodies, or courts of competent jurisdiction where we are legally compelled to do so, or where disclosure is necessary to protect the safety and rights of our players or the integrity of the Platform.

7.4 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of h789's assets, your Personal Data may be transferred to the acquiring entity. We will provide reasonable notice of any such transfer and ensure that the acquiring entity is bound by privacy obligations no less protective than those set out in this Policy.

8. Cookies & Tracking Technologies

h789 uses cookies and similar technologies to operate the Platform efficiently and deliver a personalized experience. The categories of cookies we deploy are:

• Strictly Necessary Cookies: Essential for core Platform functionality including session authentication, security tokens, and load balancing. These cannot be disabled without impairing your ability to use the Platform.
• Functional Cookies: Store your preferences such as language settings, preferred payment methods, and display options to reduce repetitive input across sessions.
• Analytics Cookies: Collect aggregated, anonymized data about how players navigate the Platform, which pages are most visited, and where users encounter errors. We use this data exclusively for internal Platform improvement.
• Security Cookies: Support our fraud-detection and bot-prevention systems by identifying unusual access patterns, ensuring that account actions are performed by a human user on a recognized device.

You may manage cookie preferences through your browser settings. Please note that disabling functional or analytics cookies may affect certain features of the Platform. We do not deploy third-party advertising or retargeting cookies on h789.

9. Data Retention

h789 retains your Personal Data only for as long as is necessary to fulfill the purposes for which it was collected or to comply with applicable legal, regulatory, and audit obligations. Our standard retention schedules are as follows:

• Active Account Data: Retained for the full duration of your Account's active status plus a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of seven (7) years from the date of each transaction, as required by international financial compliance standards.
• KYC Documents: Retained for five (5) years from account closure or the date of the last transaction, whichever is later.
• Support Communications: Retained for three (3) years from the date of the last interaction, unless the matter is subject to ongoing dispute or investigation.
• Marketing Consent Records: Retained for the duration of your consent plus two (2) years as evidence of the consent obtained.
• Technical & Usage Data (Logs): Retained for up to twelve (12) months in identifiable form; thereafter anonymized and retained indefinitely for aggregate analytics.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymized using industry-standard data destruction methods.

10. Security Measures

h789 employs a comprehensive, layered security framework to protect your Personal Data against unauthorized access, alteration, disclosure, or destruction. Our key security measures include:

• SSL/TLS Encryption: All data transmitted between your browser and the h789 Platform is encrypted using 256-bit SSL/TLS protocols, indicated by the padlock icon in your browser's address bar.
• Data Encryption at Rest: Sensitive data fields — including payment details and identity documents — are encrypted using AES-256 encryption within our database infrastructure.
• Two-Factor Authentication (2FA): Players are encouraged to enable 2FA on their accounts. All financial transactions and account-setting changes trigger a one-time verification code sent to your registered mobile number.
• Access Controls: Internal access to Personal Data is restricted on a strict need-to-know basis. All staff with access to player data undergo background screening and regular privacy-compliance training.
• Penetration Testing: The Platform undergoes periodic third-party penetration testing and vulnerability assessments to proactively identify and remediate security weaknesses.
• Incident Response: We maintain a formal data breach response plan. In the event of a breach that poses a risk to your rights and freedoms, we will notify affected players without undue delay, in accordance with applicable data-protection requirements.

11. Your Rights

As a data subject, you hold the following rights in relation to the Personal Data h789 holds about you. To exercise any of these rights, please submit a request to [email protected] with the subject line "Data Rights Request". We will respond within 30 calendar days.

• Right of Access: You may request a copy of the Personal Data we hold about you, together with information about how it is processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete Personal Data held about you.
• Right to Erasure: You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Restriction: You may request that we restrict processing of your data while a rectification or objection request is under review.
• Right to Data Portability: You may request a machine-readable copy of the Personal Data you have provided to us, for transfer to another service provider where technically feasible.
• Right to Object: You may object to processing based on legitimate interests, including profiling for marketing purposes. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

Please note that some requests may be subject to identity verification before we can act on them. Certain rights are also subject to exemptions — for example, we cannot erase data we are legally required to retain for AML or tax compliance purposes.

12. Protection of Minors

h789 is strictly an adult-only platform. We do not knowingly collect Personal Data from individuals under the age of 21. Age verification is a mandatory step during account registration, and all accounts are subject to KYC checks that confirm the player's age. If we discover that Personal Data has been collected from a person under 21, we will immediately close the associated account, void any gaming activity, and securely delete all Personal Data relating to that individual.

Parents and guardians who believe that a minor may have accessed or registered on h789 should contact us immediately at [email protected]. We take underage gambling extremely seriously and will prioritize any such report.

13. Third-Party Services

The h789 Platform may reference or integrate services provided by third parties, including game studios, payment processors, and analytics providers. h789 is not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party service you interact with independently of the h789 Platform. Our data-sharing relationships with third-party Processors are governed by formal data processing agreements, as described in Section 7.1 above.

14. Policy Amendments

h789 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, our data-processing practices, or Platform functionality. When we make material changes, we will notify registered players via email and post a prominent notice on the Platform. The "Last Updated" date at the top of this page reflects when the most recent revision was published. Your continued use of the Platform following notification of changes constitutes your acceptance of the revised Policy.

We recommend reviewing this Policy periodically to stay informed about how h789 protects your data. Archived versions of this Policy are available upon request.

15. Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or h789's data-processing practices, please contact our Data Protection team through the following channel:

When submitting a data-rights request, please include your registered username and a clear description of your request. You may be asked to complete a brief identity verification step before we process your request, to ensure we do not disclose data to an unauthorized party.