Privacy Policy

1. Introduction and Data Controller

This Privacy Policy applies to all users of the erek21 platform, including visitors to our website, registered account holders, and former customers. erek21 acts as the data controller for all personal data collected through our platform, meaning we determine the purposes and means of processing your personal information.

Our registered business entity operates under international gaming licensing jurisdictions, and we maintain data processing standards that align with global best practices including principles similar to the European Union's General Data Protection Regulation (GDPR) and Indonesian data protection guidelines. When we refer to "personal data" or "personal information" in this policy, we mean any information that identifies you as an individual or relates to an identifiable individual.

2. Information We Collect

2.1 Information You Provide Directly

When you register an account with erek21, we collect the following personal information that you provide directly:

• Identity Information: Full legal name as it appears on your Indonesian identity documents, date of birth, nationality, and gender.
• Contact Information: Email address, phone number (mobile), and residential address including city and postal code.
• Identity Verification Documents: Copies of your Indonesian national identity card (KTP), passport, or driver's license submitted for KYC (Know Your Customer) verification.
• Financial Information: Bank account details (bank name, account number, account holder name) for deposits and withdrawals; e-wallet information (OVO, DANA, GoPay account details); transaction history including deposits, withdrawals, bets placed, and winnings.
• Account Credentials: Username, password (stored in encrypted form only—we never have access to your plain-text password), and security questions if enabled.
• Communication Records: Content of your communications with our customer support team via live chat, email, or other channels; feedback, complaints, or inquiries you submit.

2.2 Information Collected Automatically

When you access and use the erek21 platform, we automatically collect certain technical and behavioral information:

• Device Information: Device type (desktop, mobile, tablet), operating system, browser type and version, screen resolution, and device identifiers.
• Connection Information: IP address, internet service provider, approximate geographic location (country, region, city), time zone, and connection type.
• Usage Data: Pages visited, games played, time spent on platform, navigation paths, click patterns, session duration, and interaction with features.
• Gaming Activity: Bets placed, game results, wagering patterns, favorite games, RTP statistics, and win/loss records.
• Cookies and Tracking Technologies: Session cookies, persistent cookies, web beacons, and similar technologies to remember your preferences, authenticate your session, and analyze platform usage. You can control cookie preferences through your browser settings, but disabling cookies may limit platform functionality.

2.3 Information from Third Parties

We may receive information about you from third-party sources including:

• Payment Processors: Transaction confirmation and payment method verification from banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay).
• Game Providers: Game session data, RTP records, and technical performance information from providers like Pragmatic Play, Evolution Gaming, and Microgaming.
• Identity Verification Services: Verification results from third-party KYC and anti-fraud services that confirm identity document authenticity.
• Marketing Partners: If you arrive at erek21 through an affiliate or marketing partner, we may receive referral information (but not your personal data unless you provide it directly to us).

3. How We Use Your Information

erek21 collects and processes your personal data for the following legitimate purposes:

3.1 Account Management and Service Delivery

• Create, maintain, and manage your erek21 account
• Authenticate your identity and prevent unauthorized access
• Process deposits, withdrawals, and internal account transfers
• Provide access to games, sports betting, and platform features
• Track your transaction history and account balance
• Manage your preferences, settings, and communication choices

3.2 Legal and Regulatory Compliance

• Verify your age (21+ requirement) and identity through KYC procedures
• Comply with anti-money laundering (AML) and counter-terrorist financing (CTF) regulations
• Detect, prevent, and investigate fraud, collusion, and terms violations
• Respond to legal requests, court orders, or regulatory inquiries
• Maintain records as required by gaming licenses and applicable laws
• Report suspicious transactions to relevant financial intelligence units

3.3 Customer Support and Communication

• Respond to your inquiries, complaints, and support requests
• Send account-related notifications (withdrawal confirmations, password resets, security alerts)
• Communicate important service updates, terms changes, or maintenance schedules
• Provide technical support and troubleshooting assistance
• Conduct customer satisfaction surveys (optional participation)

3.4 Marketing and Promotions (With Consent)

• Send promotional offers, bonuses, and VIP rewards information (only if you opt in)
• Notify you about new games, features, or tournaments that may interest you
• Provide personalized recommendations based on your gaming preferences
• Invite you to special events or seasonal promotions (Idul Fitri bonuses, Independence Day tournaments)

Note: Marketing communications are entirely optional. You can opt out at any time through account settings or by contacting support. Opting out does not affect essential account-related communications.

3.5 Platform Improvement and Analytics

• Analyze usage patterns to improve platform design and user experience
• Monitor game performance, loading times, and technical issues
• Conduct research on player behavior to develop better features
• Test new games, payment methods, or platform functionalities
• Generate aggregated, anonymized statistics for business planning

3.6 Responsible Gaming and Player Protection

• Monitor gambling patterns for signs of problem gambling or addiction
• Enforce deposit limits, loss limits, and self-exclusion requests
• Provide reality-check reminders and session time tracking
• Proactively reach out with responsible gaming resources if concerning patterns are detected
• Block underage users and enforce 21+ age restrictions

4. Legal Bases for Processing

Under international data protection standards, we process your personal data based on the following legal grounds:

• Contractual Necessity: Processing is necessary to provide the services you requested by creating an account and using erek21 (account management, payment processing, game access).
• Legal Obligation: Processing is required to comply with laws and regulations such as KYC/AML requirements, age verification, tax reporting, and regulatory audits.
• Legitimate Interests: Processing serves legitimate business interests such as fraud prevention, platform security, service improvement, and customer support, provided these interests do not override your fundamental rights.
• Consent: For optional activities like marketing communications, we obtain your explicit consent, which you can withdraw at any time without affecting other services.

5. How We Protect Your Information

5.1 Technical Security Measures

erek21 employs industry-standard security technologies and procedures to protect your personal data:

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL (Secure Socket Layer) technology—the same encryption banks use.
• Data Storage: Personal data is stored on secure servers with restricted physical and digital access. Servers are located in secure data centers with 24/7 monitoring, fire suppression, and backup power systems.
• Password Security: Your password is hashed using strong cryptographic algorithms. We never store plain-text passwords and cannot retrieve your original password—only reset it.
• Access Controls: Only authorized erek21 personnel with legitimate business need can access personal data, and all access is logged and monitored.
• Firewall Protection: Our servers are protected by enterprise-grade firewalls and intrusion detection systems that monitor and block suspicious traffic.
• Regular Security Audits: We conduct regular vulnerability assessments, penetration testing, and security audits by independent third parties.

5.2 Organizational Security Measures

• Staff undergo background checks and sign confidentiality agreements
• Employees receive regular data protection and security training
• We maintain incident response procedures for potential data breaches
• Access to personal data is granted on a need-to-know, role-based basis
• We segregate production and testing environments to prevent data leakage

5.3 Your Role in Security

While we implement robust security measures, you also play a critical role in protecting your account:

• Choose a strong, unique password and do not reuse passwords from other sites
• Never share your login credentials with anyone
• Log out after each session, especially on shared or public devices
• Keep your email account secure, as it can be used for password resets
• Notify us immediately at [email protected] if you suspect unauthorized account access
• Be cautious of phishing emails pretending to be from erek21—we never ask for passwords via email

6. Data Sharing and Disclosure

6.1 When We Share Your Information

erek21 does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your data in the following limited circumstances:

6.2 Service Providers and Business Partners

We share data with trusted third-party service providers who assist in operating our platform, subject to strict confidentiality obligations:

• Payment Processors: Banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay) receive transaction information necessary to process deposits and withdrawals.
• Game Providers: Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, and other game suppliers receive minimal data (user ID, bet amounts, game results) required to deliver gaming services.
• KYC Verification Services: Third-party identity verification providers receive copies of your identity documents to confirm authenticity and prevent fraud.
• Customer Support Tools: Live chat and email systems may be hosted by third-party providers who process support communications on our behalf.
• Analytics Providers: We use analytics services to understand platform usage, but personal data is anonymized or pseudonymized before sharing.

All third-party providers are carefully vetted, contractually bound to protect your data, and prohibited from using your information for their own purposes.

6.3 Legal Requirements and Law Enforcement

We may disclose personal data when required by law or when we believe disclosure is necessary to:

• Comply with court orders, subpoenas, or legal processes
• Respond to lawful requests from regulatory authorities or law enforcement
• Investigate or prevent fraud, security threats, or illegal activity
• Protect the rights, property, or safety of erek21, our users, or the public
• Enforce our Terms and Conditions or other agreements

6.4 Business Transfers

In the event erek21 is involved in a merger, acquisition, bankruptcy, or sale of assets, your personal data may be transferred to the successor entity. We will notify you via email and/or prominent notice on our platform before your data becomes subject to a different privacy policy.

6.5 Aggregated and Anonymized Data

We may share aggregated, anonymized data that does not identify you personally with business partners, advertisers, or the public. For example, "60% of erek21 users play slots" or "average deposit amount is Rp 500,000." This aggregated data cannot be used to identify individual users.

7. Data Retention

erek21 retains your personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce agreements.

Data Type	Retention Period	Reason
Account Information	Duration of account + 7 years	Legal and regulatory requirements
Transaction Records	7 years after transaction	Financial regulations and tax laws
Identity Documents (KYC)	7 years after last transaction	Anti-money laundering regulations
Game History	7 years	Dispute resolution and auditing
Support Communications	3 years	Customer service quality and dispute resolution
Marketing Consent Records	Until consent withdrawn + 3 years	Proof of consent compliance
Login Activity Logs	1 year	Security monitoring and fraud prevention

After retention periods expire, we securely delete or anonymize personal data. Anonymized data may be retained indefinitely for statistical and research purposes.

8. Your Privacy Rights

You have the following rights regarding your personal data. To exercise any of these rights, contact our Data Protection Officer at [email protected].

8.1 Right of Access

You have the right to request a copy of all personal data we hold about you, including account information, transaction history, identity documents, and communication records. We will provide this data in a structured, commonly used format (typically PDF or CSV). Response time: within 30 days of verified request.

8.2 Right to Rectification

If any of your personal data is inaccurate or incomplete, you have the right to request correction. You can update most information directly in your account settings (email, phone number, address). For changes to your legal name or identity documents, contact support with updated documentation.

8.3 Right to Erasure ("Right to Be Forgotten")

You may request deletion of your personal data under certain circumstances, such as when data is no longer necessary for the purposes collected, or you withdraw consent for optional processing (e.g., marketing). However, we may retain data when required by law (AML/KYC records, transaction history) or to defend legal claims. Upon account closure and expiration of retention periods, we will delete your data.

8.4 Right to Restrict Processing

You can request that we limit how we process your data in specific situations, such as while we verify the accuracy of disputed data or when you contest deletion. During restriction, we will store the data but not actively process it except with your consent or for legal purposes.

8.5 Right to Data Portability

You have the right to receive your personal data in a structured, machine-readable format (CSV, JSON) and transmit it to another service provider. This applies to data you provided to us based on consent or contract, and that we process automatically.

8.6 Right to Object

You can object to processing based on legitimate interests (e.g., marketing, analytics) at any time. You can opt out of marketing communications via account settings, unsubscribe links in emails, or by contacting support. Essential processing for service delivery and legal compliance cannot be objected to.

8.7 Right to Withdraw Consent

Where processing is based on consent (e.g., marketing emails), you can withdraw consent at any time without affecting the lawfulness of processing conducted before withdrawal. Withdrawing consent does not affect other processing based on contract or legal obligation.

8.8 Right to Lodge a Complaint

If you believe your privacy rights have been violated, you may lodge a complaint with erek21's Data Protection Officer at [email protected]. If unsatisfied with our response, you may also file a complaint with your local data protection authority or regulatory body.

9. International Data Transfers

erek21 operates internationally, and your personal data may be transferred to, stored, and processed in countries outside Indonesia, including jurisdictions where data protection laws may differ from Indonesian standards. When we transfer data internationally, we implement appropriate safeguards such as:

• Standard contractual clauses approved by international data protection authorities
• Ensuring recipient countries provide adequate data protection
• Obtaining your explicit consent for transfers where required
• Limiting data transfers to what is necessary for service delivery

By using erek21 services, you acknowledge and consent to international data transfers under these safeguards.

10. Cookies and Tracking Technologies

10.1 What Are Cookies?

Cookies are small text files placed on your device by websites you visit. They help websites remember your preferences, authenticate your session, and analyze usage patterns. erek21 uses cookies to improve your experience and platform functionality.

10.2 Types of Cookies We Use

• Essential Cookies: Required for platform operation. These authenticate your login session, remember your language preference, and enable basic features. Cannot be disabled without breaking functionality.
• Performance Cookies: Collect anonymous usage data to help us understand how visitors interact with the platform, identify technical issues, and improve performance. Example: Google Analytics.
• Functionality Cookies: Remember your choices (game favorites, notification preferences) to provide enhanced, personalized features.
• Marketing Cookies: Used to deliver relevant promotions and track campaign effectiveness. Only set if you consent to marketing communications.

10.3 Managing Cookies

You can control cookie preferences through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or receive warnings before cookies are set. However, disabling essential cookies will prevent you from using certain platform features like staying logged in. To learn how to manage cookies, visit your browser's help documentation.

11. Children's Privacy

erek21 strictly prohibits use by individuals under 21 years of age. We do not knowingly collect personal data from minors. If we discover that we have inadvertently collected data from someone under 21, we will immediately delete that data and close the account. If you believe a minor has provided data to erek21, please contact us immediately at [email protected].

12. Changes to This Privacy Policy

erek21 reserves the right to update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or platform features. Changes will be effective immediately upon publication on this page, with the "Last Updated" date revised accordingly. Material changes affecting your rights will be communicated via email or prominent notice on the platform. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.

13. Contact Information and Data Protection Officer

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact our Data Protection Officer:

• Email: [email protected] (plain text contact, not a clickable link)
• Subject Line: Include "Privacy Inquiry" or "Data Request" for priority handling
• Response Time: We aim to respond to privacy inquiries within 5 business days and complete data requests within 30 days

For all privacy-related communications, please include your erek21 username and registered email address to help us verify your identity and process your request efficiently. We may request additional verification (e.g., answering security questions) to protect against unauthorized access to your data.