Privacy Policy

1. Introduction

protog ("we," "us," or "our") operates an online gaming platform serving the Indonesian market with international standards of privacy protection. We understand that your privacy is important, and we are committed to maintaining the confidentiality and security of your personal information.

This Privacy Policy explains what information we collect, why we collect it, how we use it, and the choices you have regarding your personal data. We comply with international data protection standards and implement industry best practices to safeguard your information.

By creating an account with protog, accessing our website, or using our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.

2. Information We Collect

2.1 Information You Provide Directly

When you register for a protog account, we collect the following personal information:

• Identity Information: Full legal name, date of birth, gender, and nationality as stated on your government-issued identification documents
• Contact Information: Email address, phone number, residential address, and city of residence
• Account Credentials: Username and encrypted password for account access
• Financial Information: Bank account details (bank name, account number, account holder name), e-wallet information (OVO, DANA, GoPay account details), and payment method preferences
• Verification Documents: Copies of government-issued photo ID (Indonesian KTP, passport, driver's license), proof of address documents, and in some cases, payment method verification documents
• Communication Data: Information you provide when contacting customer support, including chat transcripts, email correspondence, and support ticket details

2.2 Information Collected Automatically

When you access or use protog services, we automatically collect certain technical and behavioral information:

• Device Information: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers
• Usage Data: Pages viewed, time spent on pages, click patterns, navigation paths, games played, bets placed, and transaction history
• Location Data: Approximate geographic location based on IP address to comply with regional restrictions and prevent fraud
• Cookies and Tracking Technologies: Session cookies, persistent cookies, web beacons, and similar technologies to enhance user experience and maintain session state (see Section 10 for detailed cookie information)
• Gaming Activity: Game selections, bet amounts, win/loss records, session duration, gameplay patterns, and responsible gaming tool usage

2.3 Information from Third Parties

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

• Payment processors and financial institutions regarding deposit and withdrawal transactions
• Identity verification service providers who assist with KYC compliance
• Fraud prevention and risk management services
• Marketing partners (only with your explicit consent)

3. How We Use Your Information

protog uses your personal information for the following legitimate business purposes:

3.1 Account Management and Service Delivery

• Creating and maintaining your protog account
• Verifying your identity and age to ensure compliance with 21+ age restrictions
• Processing deposits, withdrawals, and other financial transactions
• Providing access to gaming services including casino games, sports betting, and togel lottery markets
• Managing bonus offers, promotions, and loyalty rewards
• Maintaining transaction records and account balance information

3.2 Communication and Customer Support

• Responding to your inquiries, support requests, and feedback
• Sending account-related notifications including transaction confirmations, balance updates, and security alerts
• Providing customer service via live chat, email, WhatsApp, and Telegram
• Sending service announcements, platform updates, and important policy changes

3.3 Legal and Regulatory Compliance

• Complying with Know Your Customer (KYC) and anti-money laundering (AML) regulations
• Preventing fraud, money laundering, and other illegal activities
• Enforcing our Terms and Conditions and detecting violations
• Responding to legal requests from law enforcement and regulatory authorities
• Maintaining records required by gaming license conditions

3.4 Platform Improvement and Analytics

• Analyzing user behavior to improve platform functionality and user experience
• Testing new features and optimizing website performance
• Conducting research and statistical analysis to understand user preferences
• Developing new products, services, and gaming content

3.5 Responsible Gaming

• Monitoring gaming behavior to identify potential problem gambling patterns
• Implementing responsible gaming tools including deposit limits, loss limits, and self-exclusion
• Providing support resources and intervention when problematic gambling behavior is detected

3.6 Marketing Communications (With Your Consent)

• Sending promotional offers, bonus notifications, and marketing materials (only if you opt in)
• Personalizing marketing content based on your gaming preferences
• Conducting customer satisfaction surveys and feedback requests

Note: You can opt out of marketing communications at any time by clicking the unsubscribe link in promotional emails or adjusting your communication preferences in account settings.

4. Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Contractual Necessity: Processing is necessary to fulfill our contractual obligations to provide gaming services as outlined in our Terms and Conditions
• Legal Compliance: Processing is required to comply with legal obligations including KYC/AML regulations, age verification, and gaming license conditions
• Legitimate Interests: Processing serves our legitimate business interests such as fraud prevention, platform security, service improvement, and customer support
• Consent: For marketing communications and non-essential cookies, we obtain your explicit consent before processing

5. Information Sharing and Disclosure

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

5.1 Service Providers

We engage trusted third-party service providers to perform functions on our behalf, including:

• Payment processing companies (to handle deposits and withdrawals via BCA, BRI, BNI, Mandiri, and e-wallets)
• Identity verification services (for KYC compliance)
• Cloud hosting and data storage providers
• Customer support platforms
• Analytics and performance monitoring services
• Fraud detection and prevention services

These service providers are contractually obligated to protect your information and use it only for the specific purposes we authorize.

5.2 Game Providers

Certain information may be shared with gaming software providers (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, etc.) to facilitate gameplay, verify game outcomes, and maintain gaming records. Game providers are bound by strict confidentiality agreements.

5.3 Legal Requirements

We may disclose your information when required by law or in response to:

• Valid legal processes such as subpoenas, court orders, or regulatory requests
• Investigations by law enforcement or gaming regulatory authorities
• Circumstances where disclosure is necessary to protect our rights, property, or safety, or that of our users or the public
• Suspected fraud, money laundering, or other illegal activities

5.4 Business Transfers

In the event protog undergoes a merger, acquisition, sale of assets, or bankruptcy proceeding, your personal information may be transferred to the successor entity. You will be notified via email and/or prominent notice on our website of any such change in ownership or control of your personal information.

5.5 With Your Consent

We may share your information with other parties when you have given us explicit permission to do so.

6. Data Security

protog takes the security of your personal information extremely seriously and employs industry-standard security measures to protect against unauthorized access, alteration, disclosure, or destruction of data.

6.1 Technical Security Measures

• Encryption: All data transmission between your device and protog servers is protected by 256-bit SSL (Secure Socket Layer) encryption, the same technology used by major financial institutions
• Data Encryption at Rest: Sensitive personal and financial information is encrypted when stored in our databases
• Firewalls and Intrusion Detection: Advanced firewall systems and intrusion detection software monitor and protect our servers 24/7
• Secure Data Centers: Data is stored in PCI DSS Level 1 compliant data centers with physical security controls including 24/7 surveillance, biometric access controls, and environmental safeguards
• Regular Security Audits: Independent security experts conduct regular penetration testing and vulnerability assessments

6.2 Organizational Security Measures

• Access to personal data is restricted to authorized employees and contractors who require access to perform their job functions
• All staff members with access to personal data undergo security training and are bound by strict confidentiality agreements
• Multi-factor authentication is required for administrative access to sensitive systems
• Comprehensive logging and monitoring systems track all access to personal data

6.3 Your Security Responsibilities

While protog implements robust security measures, you also play a crucial role in protecting your account:

• Choose a strong, unique password and never share it with anyone
• Enable two-factor authentication (2FA) when available
• Log out after each session, especially on shared or public devices
• Keep your contact information up to date so we can reach you about security issues
• Immediately notify us if you suspect unauthorized account access

Important: Despite our security measures, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.

7. Data Retention

protog retains your personal information only as long as necessary to fulfill the purposes described in this Privacy Policy and comply with legal and regulatory requirements.

7.1 Retention Periods

• Active Accounts: Personal information for active accounts is retained for the duration of your account relationship with protog
• Inactive Accounts: Accounts inactive for 12+ months may have non-essential data archived or deleted, while transaction records are retained for legal compliance
• Closed Accounts: Following account closure, we retain certain information for up to 7 years to comply with anti-money laundering regulations, tax laws, and to resolve disputes or legal claims
• Transaction Records: Financial transaction data is retained for a minimum of 7 years as required by financial regulations
• Communication Records: Customer support interactions are retained for up to 3 years for quality assurance and dispute resolution

7.2 Data Deletion

After applicable retention periods expire, we securely delete or anonymize your personal information using industry-standard methods to prevent recovery or reconstruction. Anonymized data may be retained indefinitely for statistical analysis and research purposes.

8. Your Privacy Rights

As a protog user, you have the following rights regarding your personal information:

8.1 Right to Access

You have the right to request a copy of the personal information we hold about you. You can view much of this information directly in your account dashboard. To request a comprehensive data export, contact our support team at [email protected].

8.2 Right to Rectification

You can update or correct your personal information at any time through your account settings. If you cannot make changes directly, contact customer support for assistance. We will update your information within 5 business days.

8.3 Right to Erasure (Right to be Forgotten)

You may request deletion of your personal data, subject to the following conditions:

• We will comply with deletion requests after applicable legal retention periods expire
• We may retain information necessary to comply with legal obligations, resolve disputes, prevent fraud, or enforce our Terms and Conditions
• Deletion requests are processed within 30 days, and you will receive confirmation when complete

8.4 Right to Restrict Processing

You may request that we limit how we use your personal data in certain circumstances, such as while we verify data accuracy or assess the legality of processing.

8.5 Right to Data Portability

You have the right to receive your personal data in a structured, machine-readable format and transmit it to another service provider where technically feasible.

8.6 Right to Object

You can object to processing of your personal data for marketing purposes at any time. To opt out of marketing communications, click unsubscribe links in emails or adjust preferences in your account settings.

8.7 Right to Withdraw Consent

Where we rely on your consent to process personal data, you may withdraw that consent at any time. This does not affect the lawfulness of processing before consent withdrawal.

8.8 Exercising Your Rights

To exercise any of these rights, contact us at [email protected] with your account details and specific request. We will respond within 30 days and may request additional information to verify your identity before processing sensitive requests.

9. International Data Transfers

protog operates as an internationally licensed platform serving the Indonesian market. Your personal information may be transferred to and processed in countries outside Indonesia where our servers, service providers, or game providers are located. These countries may have data protection laws different from Indonesian regulations.

When we transfer your data internationally, we ensure appropriate safeguards are in place, including:

• Contracts with service providers that mandate data protection standards equivalent to this Privacy Policy
• Use of secure data transfer protocols and encryption
• Compliance with international data protection frameworks

By using protog services, you consent to the international transfer and processing of your personal information as described in this policy.

10. Cookies and Tracking Technologies

10.1 What Are Cookies

Cookies are small text files stored on your device when you visit websites. They help websites remember your preferences, maintain your login session, and provide analytics about site usage.

10.2 How protog Uses Cookies

We use the following types of cookies:

• Essential Cookies: Required for basic site functionality including login authentication, session management, and security features. These cookies cannot be disabled without preventing site functionality.
• Performance Cookies: Collect anonymous information about how you use protog, including pages visited, time spent, and errors encountered. This helps us improve website performance.
• Functional Cookies: Remember your preferences such as language selection, display settings, and game favorites to enhance user experience.
• Analytics Cookies: Provide detailed usage statistics to help us understand user behavior patterns and optimize platform design (only with your consent).

10.3 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or receive alerts when cookies are set. Note that disabling essential cookies may prevent you from accessing certain protog features or services.

Browser cookie settings are typically found under Privacy or Security menus. Consult your browser's help documentation for specific instructions.

11. Children's Privacy

protog services are strictly intended for adults aged 21 and over. We do not knowingly collect personal information from individuals under 21 years of age. If we become aware that we have inadvertently collected information from someone under 21, we will immediately delete that information from our systems.

All users must complete age verification during the KYC process before their first withdrawal. If you believe a minor has accessed protog services, please contact us immediately at [email protected] so we can take appropriate action.

12. Third-Party Links

The protog website may contain links to third-party websites, including game provider sites, payment processor sites, and responsible gaming resources. This Privacy Policy applies only to protog services. We are not responsible for the privacy practices of third-party websites.

When you leave the protog platform via external links, we encourage you to review the privacy policies of those third-party sites to understand how they collect, use, and share your information.

13. Changes to This Privacy Policy

protog reserves the right to modify or 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 policy
• Notify you via email to your registered email address
• Display a prominent notice on the protog website
• For significant changes affecting your rights, request your renewed consent where required by law

Your continued use of protog services after policy changes constitutes acceptance of the updated Privacy Policy. We recommend reviewing this page periodically to stay informed about how we protect your information.

14. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us:

• Email: [email protected]
• Live Chat: Available 24/7 on the protog website
• WhatsApp: Available 24/7 (contact details on website)
• Subject Line: Please use "Privacy Inquiry" in email subject lines for faster routing

Our Indonesian-speaking customer support team will respond to privacy inquiries within 48 hours during business days. For urgent security concerns related to unauthorized account access, contact us immediately via live chat for fastest response.

We take all privacy concerns seriously and will work diligently to address your questions and resolve any issues regarding the handling of your personal information.