Privacy Policy

halo69 ("we", "us", "our") operates an online gaming platform accessible at halo69.cam (the "Platform"). We are committed to protecting the privacy and security of all personal data we collect from our Members and visitors. This Privacy Policy applies to all users of the Platform, whether registered Members or casual visitors browsing our website.

This Privacy Policy should be read in conjunction with our Terms & Conditions. Where there is any conflict between this Privacy Policy and the Terms & Conditions, the Terms & Conditions shall prevail to the extent of the inconsistency.

We reserve the right to update this Privacy Policy at any time. Material changes will be communicated through a notice on the Platform or via email. Continued use of the Platform following such notice constitutes acceptance of the revised Privacy Policy.

For the purposes of applicable data protection laws, halo69 is the data controller responsible for your personal information. This means we determine the purposes and means of processing your personal data and are accountable for its lawful, fair, and transparent handling.

If you have questions about how your personal data is processed or wish to exercise any of your data protection rights, you may contact us at:

• Email: [email protected]
• Subject Line: "Privacy Inquiry" or "Data Protection Request"

We collect several categories of personal information necessary to provide our Services, comply with legal obligations, and improve user experience. The types of data we collect include:

3.1 Registration & Account Information. When you create an account on halo69, we collect:

• Full legal name
• Date of birth (to verify 21+ age requirement)
• Email address
• Mobile phone number
• Residential address (city, province, postal code)
• Username and encrypted password
• Preferred currency (Indonesian Rupiah / IDR)

3.2 Identity Verification (KYC) Documents. To comply with anti-money laundering regulations and responsible gaming requirements, we collect:

• Government-issued photo ID (Indonesian KTP or passport)
• Proof of address documents (utility bills, bank statements)
• Photographs or scans of identity documents
• Selfie photographs for facial verification (where required)

3.3 Financial & Transaction Data. When you make deposits or withdrawals, we collect:

• Bank account name and account number (BCA, BRI, BNI, Mandiri, etc.)
• E-wallet account information (OVO, DANA, GoPay, ShopeePay)
• Payment card details (last 4 digits only; full card numbers are processed by secure third-party payment gateways)
• Transaction history, deposit amounts, withdrawal requests, and timestamps
• Bonus claims, wagering history, and promotional activity

3.4 Gaming Activity & Behavioral Data. We automatically collect information about how you use the Platform, including:

• Games played, bet amounts, win/loss records, and session duration
• Betting patterns and gameplay statistics
• Responsible gaming tool usage (deposit limits, self-exclusion status)
• Customer support interactions and chat transcripts

3.5 Technical & Device Information. When you access the Platform, we automatically collect:

• IP address and geolocation data
• Device type, operating system, and browser type
• Screen resolution, language settings, and time zone (WIB / WITA / WIT)
• Cookies and similar tracking technologies (see Section 10)
• Referral source (how you found halo69)
• Log files recording page visits, clickstream data, and error reports

3.6 Communications. If you contact our customer support team via email, live chat, or phone, we may record and store:

• The content of your messages
• Support ticket history and resolution notes
• Feedback, complaints, and survey responses

halo69 processes your personal data for the following purposes:

• Account Management: To create, maintain, and administer your Member Account; to authenticate your identity when you log in; to process password resets and account recovery requests.
• Service Provision: To enable you to place bets, play games, participate in promotions, and access all features of the Platform.
• Payment Processing: To process deposits, execute withdrawal requests, verify payment methods, and maintain transaction records.
• KYC & Compliance: To verify your identity and age (21+ requirement), prevent underage gambling, comply with anti-money laundering (AML) regulations, detect and prevent fraud, and fulfill regulatory reporting obligations.
• Customer Support: To respond to your inquiries, resolve technical issues, handle complaints, and provide assistance via live chat, email, or phone.
• Responsible Gaming: To monitor your gaming behavior for signs of problem gambling, enforce self-exclusion requests, apply deposit and loss limits, and provide access to responsible gaming resources.
• Marketing & Promotions: To send you promotional offers, bonus announcements, newsletters, and personalized communications based on your gaming preferences (only where you have consented to receive such communications).
• Platform Improvement: To analyze user behavior, identify trends, optimize game offerings, improve website functionality, and develop new features.
• Security & Fraud Prevention: To detect and prevent fraudulent activity, collusion, bonus abuse, unauthorized account access, and other security threats.
• Legal Obligations: To comply with applicable laws, regulations, court orders, and governmental requests; to enforce our Terms & Conditions; to protect our legal rights and interests.

We process your personal data only when we have a lawful basis to do so. Depending on the purpose, we rely on one or more of the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you (the Terms & Conditions) — for example, to provide gaming services, process transactions, and maintain your Account.
• Legal Obligation: Processing is required to comply with applicable laws and regulations, including KYC verification, AML checks, age verification, and responsible gaming enforcement.
• Legitimate Interests: Processing is necessary for our legitimate business interests — such as fraud prevention, security monitoring, customer support, platform improvement, and direct marketing — provided these interests do not override your fundamental rights and freedoms.
• Consent: Where required by law, we obtain your explicit consent before processing certain categories of data (e.g., marketing communications, optional cookies). You may withdraw consent at any time through your Account settings.

halo69 does not sell, rent, or trade your personal data to third parties. However, we may share your information with trusted partners and service providers in the following circumstances:

• Payment Processors: We share payment-related data with banks, e-wallet providers, and payment gateways (e.g., BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, Visa, Mastercard processors) to facilitate deposits and withdrawals. These providers process data under strict confidentiality and security obligations.
• KYC & Verification Providers: We may share identity documents with third-party KYC verification services to confirm your age, identity, and address. These providers operate under data protection agreements and retain data only as long as necessary for verification purposes.
• Game Providers: Gaming activity data is shared with our licensed game suppliers (Evolution Gaming, Pragmatic Play, Microgaming, NetEnt, etc.) to deliver live casino, slot, and table games. These providers use data solely to operate their games and do not use it for independent marketing.
• Customer Support Tools: We may use third-party helpdesk platforms and live chat software to manage customer inquiries. Support conversations are stored securely and used only to improve service quality.
• Analytics & Marketing Partners: With your consent, we may share anonymized or aggregated data with analytics platforms to measure marketing effectiveness and understand user behavior. No personally identifiable information is shared for marketing purposes without your explicit opt-in.
• Legal & Regulatory Authorities: We may disclose your data to law enforcement, regulators, courts, or government agencies when required by law, to comply with legal processes, to enforce our Terms, or to protect the rights, property, or safety of halo69, our Members, or the public.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections outlined in this Policy.

All third-party partners are contractually obligated to handle your data securely, use it only for specified purposes, and comply with applicable data protection laws.

halo69 employs industry-leading security measures to protect your personal data from unauthorized access, disclosure, alteration, and destruction. Our security infrastructure includes:

• Encryption: All data transmitted between your device and our servers is encrypted using TLS/SSL protocols. Sensitive data stored in our databases (passwords, payment details) is encrypted at rest.
• Access Controls: Access to personal data is restricted to authorized personnel only, based on role-based permissions. Employees undergo regular security training and are bound by confidentiality agreements.
• Monitoring & Logging: We continuously monitor our systems for suspicious activity, unauthorized access attempts, and security vulnerabilities. All access to sensitive data is logged and audited.
• Third-Party Audits: Our security practices are regularly reviewed by independent security auditors and penetration testers to identify and remediate potential weaknesses.
• Incident Response: In the unlikely event of a data breach, we have an incident response plan in place to contain the breach, assess the impact, notify affected users, and report to relevant authorities as required by law.

While we implement robust security measures, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security but are committed to protecting your data to the best of our ability.

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Account Data: Retained for the duration of your active Account, plus an additional period as required by applicable regulations (typically 5–7 years after Account closure for financial and compliance records).
• Transaction Records: Financial transaction data is retained for at least 7 years to comply with anti-money laundering regulations and tax reporting requirements.
• KYC Documents: Identity verification documents are retained for 7 years following Account closure or the last transaction, whichever is later, in accordance with regulatory requirements.
• Marketing Communications: If you unsubscribe from marketing emails, your email address is retained on our suppression list indefinitely to honor your opt-out preference.
• Technical Logs: Server logs, IP addresses, and device information are typically retained for 12–24 months for security and troubleshooting purposes.
• Support Records: Customer support transcripts and tickets are retained for 3 years to maintain service quality and resolve disputes.

After the applicable retention period expires, we securely delete or anonymize your personal data so it can no longer identify you.

Depending on your jurisdiction, you may have the following rights regarding your personal data. To exercise any of these rights, contact us at [email protected] with "Data Rights Request" in the subject line:

• Right of Access: You may request a copy of the personal data we hold about you. We will provide this information in a commonly used electronic format within 30 days of your request.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request correction. You can also update most account information directly through your Account settings.
• Right to Erasure (Right to Be Forgotten): You may request deletion of your personal data where there is no compelling legal or contractual reason for us to retain it. Note that certain data must be retained to comply with regulatory obligations.
• Right to Restriction of Processing: You may request that we limit how we use your data in certain circumstances (e.g., while we verify the accuracy of data you have disputed).
• Right to Data Portability: You may request that we transfer your data to another service provider in a structured, machine-readable format where technically feasible.
• Right to Object: You may object to processing of your data for direct marketing purposes at any time. You may also object to processing based on legitimate interests by providing specific reasons related to your situation.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time through your Account settings or by contacting us. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.
• Right to Lodge a Complaint: If you believe we have mishandled your personal data, you have the right to lodge a complaint with your local data protection authority.

We will respond to all valid requests within 30 days. In some cases, we may ask you to verify your identity before processing your request to protect your data from unauthorized access.

halo69 uses cookies and similar tracking technologies to enhance your browsing experience, analyze site traffic, and deliver personalized content. A cookie is a small text file stored on your device that helps us recognize you on return visits.

Types of Cookies We Use:

• Essential Cookies: Required for core Platform functionality such as login sessions, security features, and load balancing. These cookies cannot be disabled as the Platform will not function properly without them.
• Performance Cookies: Collect anonymous information about how visitors use the Platform (pages visited, time spent, error messages) to help us improve performance and user experience.
• Functional Cookies: Remember your preferences (language, currency, display settings) to provide a personalized experience across sessions.
• Targeting/Advertising Cookies: Track your activity across websites to deliver personalized marketing messages and measure ad effectiveness. These cookies are only used with your consent.

Managing Cookies: You can control cookie settings through your browser preferences. Most browsers allow you to block or delete cookies, though disabling essential cookies may prevent certain features from working. Disabling performance and functional cookies may reduce site functionality. You can withdraw consent for non-essential cookies at any time through your Account cookie settings.

The halo69 Platform may contain links to third-party websites, services, or payment providers. This Privacy Policy applies only to data collected by halo69. We are not responsible for the privacy practices of third-party sites. We encourage you to review the privacy policies of any external sites you visit.

Third-party game providers (Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, etc.) may set their own cookies and collect data when you play their games. These providers are independent data controllers for the data they collect directly and operate under their own privacy policies.

Your personal data may be transferred to, stored in, and processed in countries outside of Indonesia where our servers, service providers, or partners are located. These countries may have different data protection laws than Indonesia.

Where we transfer data internationally, we ensure that appropriate safeguards are in place to protect your data, such as:

• Standard contractual clauses approved by relevant data protection authorities;
• Data processing agreements with third parties that require equivalent levels of data protection;
• Transfers to countries recognized as providing adequate data protection standards.

By using the Platform, you acknowledge and consent to the transfer of your data as described in this section.

halo69 is strictly an adults-only platform. Our services are available only to individuals who are at least 21 years of age. We do not knowingly collect personal data from anyone under 21.

If we become aware that we have inadvertently collected personal data from a person under 21, we will immediately delete that data, close the associated Account, and forfeit any funds in the Account. If you believe a minor has registered on our Platform, contact us immediately at [email protected].

halo69 reserves the right to update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. When we make material changes, we will:

• Update the "Last Updated" date at the top of this page;
• Notify you via email to the address associated with your Account;
• Display a prominent notice on the Platform for at least 30 days after the change.

Continued use of the Platform after such notification constitutes your acceptance of the revised Privacy Policy. We encourage you to review this page periodically to stay informed about how we protect your data.

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact our Data Protection team:

• Email: [email protected]
• Subject Line: "Privacy Inquiry" or "Data Protection Request"
• Live Chat: Available 24/7 via the Platform
• Response Time: We aim to respond to all privacy inquiries within 48 hours, with full resolution within 30 days

Our support team is available in both English and Indonesian (Bahasa Indonesia) to assist with any privacy-related questions or data rights requests.