Privacy Policy

1. Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information that identifies or could reasonably be used to identify you as an individual, such as your name, date of birth, email address, phone number, bank account number, or IP address.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, or deletion.
• "Data Controller" refers to um155, which determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of um155 under a written agreement.
• "Cookies" means small data files placed on your device by a website to remember your preferences and track your activity.
• "KYC" (Know Your Customer) refers to the identity verification process required by um155 to confirm the identity of registered users.
• "You" or "User" means any individual who accesses or uses the um155 platform.

2. Data Controller

um155 acts as the Data Controller for all Personal Data collected through the um155 platform. As the Data Controller, um155 is responsible for ensuring that your Personal Data is processed lawfully, fairly, and transparently, in accordance with this Privacy Policy and applicable data protection laws.

For any questions or concerns about how um155 processes your Personal Data, you may contact our Data Protection team at [email protected].

3. Personal Data We Collect

um155 collects the following categories of Personal Data from users:

3.1 Identity and Contact Information

• Full legal name as it appears on your government-issued ID.
• Date of birth (to verify that you are at least 21 years of age).
• Residential address (city, province, postal code, country).
• Email address and mobile phone number.
• Username and encrypted account password.

3.2 Identity Verification (KYC) Documents

• Indonesian National ID card (KTP) or passport scan.
• Driver's license or other government-issued photo identification.
• Proof of address (utility bill, bank statement dated within 3 months).
• Proof of payment method (bank account statement, e-wallet screenshot).
• Selfie or live video for liveness verification where required.

3.3 Financial and Transaction Data

• Bank account details for deposits and withdrawals (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, and other supported banks).
• E-wallet identifiers (OVO, DANA, GoPay account phone numbers or usernames).
• Deposit and withdrawal history, amounts, and timestamps.
• Bet history, game activity, wagering totals, and account balance.

3.4 Technical and Device Data

• IP address and approximate geographic location.
• Device type, operating system, and browser type/version.
• Session duration, pages visited, and navigation patterns.
• Login timestamps and access logs.

3.5 Communication Data

• Live chat transcripts and email correspondence with um155 support.
• Feedback, complaint records, and dispute resolution notes.

4. How We Collect Your Data

um155 collects your Personal Data through the following channels:

4.1 Directly From You

We collect data that you provide directly when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions.

4.2 Automatically During Platform Use

We automatically collect technical and usage data when you access the um155 platform, including through cookies, log files, analytics tools, and device fingerprinting technology. This data is collected to ensure platform security, prevent fraud, and improve the user experience.

4.3 From Third Parties

We may receive data from third parties including:

• Payment processors and banks: Transaction confirmation data from BCA, BRI, BNI, Mandiri, CIMB Niaga, and e-wallet providers (OVO, DANA, GoPay).
• Identity verification providers: Data from third-party KYC service providers used to verify the authenticity of identity documents.
• Fraud prevention services: Risk scores and behavioral data from anti-fraud partners.
• Analytics providers: Aggregated usage statistics to help us understand how users interact with the um155 platform.

5. Purpose and Legal Basis for Processing

um155 processes your Personal Data for the following purposes and on the following legal bases:

5.1 Contract Performance

We process your Personal Data to fulfill our contractual obligations to you, including:

• Creating and managing your um155 account.
• Processing deposits, withdrawals, and bet settlements.
• Providing access to games, sports betting, and other platform features.
• Delivering customer support and resolving disputes.

5.2 Legal Compliance

We process Personal Data where required by law, including for anti-money laundering (AML) compliance, identity verification (KYC), fraud prevention, and responsible gaming obligations. We may be required to retain certain data for mandatory regulatory reporting periods.

5.3 Legitimate Interests

We process certain data based on our legitimate interests in operating a safe, secure, and fair platform. This includes monitoring for fraud and abuse, improving platform performance, and ensuring the integrity of our betting markets.

5.4 Consent

For certain data processing activities—such as sending promotional emails or placing non-essential cookies—we rely on your explicit consent. You may withdraw your consent at any time by contacting our support team or updating your account preferences, without affecting the lawfulness of processing based on consent before withdrawal.

6. Data Sharing and Disclosure

um155 does not sell your Personal Data. We may share your data in the following limited circumstances:

6.1 Service Providers

We share Personal Data with trusted third-party service providers who assist us in operating the um155 platform, including payment processors, KYC verification providers, cloud hosting providers, fraud detection partners, and customer support platforms. All service providers are contractually bound to process data only on our instructions and in compliance with applicable data protection law.

6.2 Legal Obligations

We may disclose your Personal Data to law enforcement, regulatory authorities, or government bodies when required by law or court order. This includes disclosures required under anti-money laundering regulations, tax reporting obligations, or criminal investigations.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your Personal Data may be transferred to the acquiring entity. We will notify you of any such transfer and your rights in connection with it.

6.4 No Other Sharing

Beyond the circumstances described in Sections 6.1 through 6.3, um155 will not disclose your Personal Data to any third party without your prior explicit consent.

7. Data Retention

um155 retains 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. The following general retention periods apply:

• Account data and KYC documents: Retained for a minimum of 5 years following account closure, in accordance with anti-money laundering regulatory requirements.
• Transaction and bet history: Retained for a minimum of 5 years from the date of each transaction.
• Customer support communications: Retained for 3 years from the date of last interaction.
• Technical and device data (logs): Retained for 12 months, after which logs are anonymized or deleted.
• Cookie data: Retained according to the specific cookie type and expiry period (see Section 8).

When Personal Data is no longer required, um155 will securely delete or anonymize it in accordance with our internal data disposal procedures.

8. Cookies and Tracking Technologies

8.1 What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They allow the website to remember your preferences, maintain your session, and collect usage statistics. um155 uses cookies and similar technologies to provide a secure, personalized, and functional platform experience.

8.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the platform to function correctly. These cookies enable you to log in, maintain your session, and access secure areas of um155. They cannot be disabled.
• Performance Cookies: Used to collect anonymous data on how users interact with um155, such as pages visited and error messages. This data helps us improve platform performance.
• Functionality Cookies: Remember your preferences, such as language settings, currency display, and login details (if you choose to save them).
• Analytics Cookies: Used by third-party analytics tools to measure platform traffic, user behavior, and engagement patterns on an aggregated, anonymized basis.

8.3 Managing Cookies

You can control or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the um155 platform. Instructions for managing cookies in popular browsers (Chrome, Firefox, Safari, Edge) are available in each browser's help documentation. You may also update your cookie preferences by contacting our support team.

9. Your Data Rights

As a user of um155 and a resident of Indonesia, you have the following rights with respect to your Personal Data:

• Right of Access: You have the right to request a copy of the Personal Data um155 holds about you, along with information about how it is being used.
• Right to Rectification: If any Personal Data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it.
• Right to Erasure: You may request that we delete 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 the processing of your Personal Data in certain circumstances, such as while a dispute is being resolved.
• Right to Data Portability: You have the right to receive your Personal Data in a structured, commonly used, and machine-readable format and to transmit it to another service provider where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to Object: You may object to the processing of your Personal Data where we rely on legitimate interests as the legal basis, unless we can demonstrate compelling legitimate grounds that override your interests.

10. Data Security Measures

um155 implements a comprehensive set of technical and organizational measures to protect your Personal Data from unauthorized access, loss, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS Encryption: All data in transit between your device and our servers is encrypted using industry-standard SSL/TLS protocols.
• Encryption at Rest: Sensitive Personal Data, including KYC documents and financial data, is encrypted when stored on our servers.
• Access Controls: Access to Personal Data is restricted to authorized um155 personnel on a strict need-to-know basis. All staff with access to Personal Data undergo regular data security training.
• Two-Factor Authentication (2FA): um155 supports and encourages the use of 2FA for all user accounts to prevent unauthorized login attempts.
• Intrusion Detection: Our servers are monitored 24/7 by automated intrusion detection and anomaly-detection systems.
• Regular Security Audits: We conduct periodic internal and third-party security audits and penetration tests to identify and remediate vulnerabilities.
• Data Breach Response: In the event of a data breach that poses a risk to your rights and freedoms, um155 will notify affected users and relevant authorities within 72 hours of becoming aware of the breach, in accordance with applicable law.

While we implement all reasonable measures to protect your data, no system is entirely immune to security risks. We encourage you to use a strong, unique password for your um155 account and to enable two-factor authentication to further protect your account.

11. Children and Minors

um155 is strictly an adults-only platform. We do not knowingly collect, process, or retain Personal Data from individuals under the age of 21. Access to um155 services is prohibited for anyone under 21 years of age.

If we become aware that Personal Data has been collected from a user under the age of 21, we will immediately close the associated account, delete all associated Personal Data, and—where applicable—forfeit any deposits or winnings in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that a minor has registered an account on um155, please contact us immediately at [email protected] so we can take prompt action.

12. International Data Transfers

um155 may transfer your Personal Data to servers or service providers located outside of Indonesia in order to deliver our platform and services effectively. When we transfer Personal Data internationally, we take all reasonable steps to ensure that your data receives a level of protection consistent with this Privacy Policy and applicable data protection law. Such steps may include:

• Entering into data processing agreements with third-party service providers that include appropriate data protection clauses.
• Transferring data only to jurisdictions that provide an adequate level of data protection as determined by applicable regulatory guidance.
• Applying technical safeguards such as encryption to protect data during international transfer.

By using the um155 platform, you acknowledge and consent to the transfer of your Personal Data outside Indonesia in accordance with the terms of this Privacy Policy.

13. Changes to This Privacy Policy

um155 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When we make material changes, we will:

• Update the "Last Updated" date at the top of this page.
• Display a prominent notice on the um155 platform informing users of the change.
• Where required by law or the significance of the change, notify registered users directly via email.

Your continued use of um155 following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this page periodically to stay informed about how we protect your data.

14. Contact Information

If you have any questions, concerns, or requests relating to this Privacy Policy or the way um155 handles your Personal Data, please contact our Data Protection team through any of the following channels:

• Email: [email protected]
• Subject Line: "Privacy Inquiry" or "Data Rights Request"
• Live Chat: Available 24/7 via the um155 platform
• Response Time: We aim to acknowledge all privacy-related inquiries within 2 business days and provide a full response within 30 days.

For urgent security concerns—such as suspected unauthorized access to your account or a potential data breach—please contact us immediately via live chat for the fastest response.