Privacy Policy

1. Introduction

1.1 paca91 ("we", "us", "our", "the Platform") operates an online betting and gaming platform accessible at paca91.cam. We are committed to protecting the privacy and security of our users' personal information in accordance with applicable data protection laws and international best practices.

1.2 This Privacy Policy describes how paca91 collects, uses, stores, shares, and protects personal data provided by users ("you", "your", "the Player") of the paca91 platform. It applies to all interactions with the platform, including account registration, gameplay, deposits, withdrawals, and customer support communications.

1.3 This Privacy Policy should be read in conjunction with our Terms & Conditions and Responsible Gaming policy, which together form the complete legal framework governing your use of paca91.

2. Information We Collect

2.1 Registration Data: When you create a paca91 account, we collect basic identification information including your full legal name, date of birth, email address, phone number, residential address, and preferred currency (IDR). This information is necessary to establish your account and verify your eligibility to use the platform.

2.2 Identity Verification (KYC) Data: To comply with anti-money laundering (AML) regulations and prevent underage gambling, we collect copies of government-issued identification documents (Indonesian national identity card, passport, or driver's license), proof of address documents (utility bills, bank statements), and proof of payment method ownership. All KYC documents are encrypted and stored securely in accordance with Section 7 of this policy.

2.3 Financial Data: We collect information about your deposits, withdrawals, and account balance transactions, including payment method details (bank account numbers, e-wallet identifiers). We do not store full credit card numbers or CVV codes. Payment processing is handled by certified third-party payment processors who maintain PCI-DSS compliance.

2.4 Gameplay and Betting Data: We log all bets placed, games played, outcomes, winnings, losses, bonus usage, and wagering progress. This data is essential for settling bets, processing payouts, detecting fraud, ensuring responsible gaming compliance, and resolving disputes.

2.5 Technical Data: When you access the paca91 platform, we automatically collect technical information including your IP address, device type, operating system, browser type and version, screen resolution, time zone setting, browser plug-in types, and connection information. We also collect data on pages viewed, clickstream data, and time spent on each page to improve user experience.

2.6 Communication Data: We retain records of all communications between you and paca91, including customer support tickets, live chat transcripts, and email correspondence. This data is used to improve service quality, train support staff, and provide evidence in the event of disputes.

2.7 Marketing Preferences: If you opt in to receive promotional communications, we collect your marketing preferences and track engagement with marketing emails (open rates, click-through rates) to personalize future offers.

3. How We Use Your Data

3.1 paca91 uses your personal data for the following purposes, all of which are necessary to provide and improve our gaming services:

• Account Management: To create, maintain, and secure your user account; to verify your identity and age; to process account updates and closure requests.
• Transaction Processing: To process deposits, withdrawals, and internal transfers; to maintain accurate account balance records; to apply bonuses and wagering requirements; to issue refunds where applicable.
• Game Provision: To provide access to sports betting markets, live casino tables, togel draws, slot games, and other gambling products; to settle bets and credit winnings; to maintain game history and transaction logs.
• Fraud Prevention and Security: To detect and prevent fraud, money laundering, collusion, bonus abuse, underage gambling, and other prohibited activities; to monitor for unusual betting patterns; to enforce our Terms & Conditions.
• Responsible Gaming: To monitor your gambling behavior for signs of problem gambling; to enforce deposit limits, loss limits, and self-exclusion periods you have set; to intervene proactively if we detect harmful gambling patterns.
• Customer Support: To respond to inquiries, complaints, and technical support requests; to resolve disputes; to provide personalized assistance where needed.
• Legal Compliance: To comply with applicable gaming regulations, anti-money laundering laws, tax reporting requirements, and other legal obligations; to respond to lawful requests from law enforcement and regulatory authorities.
• Platform Improvement: To analyze user behavior and preferences; to optimize platform performance; to develop new features and products; to conduct A/B testing and user research.
• Marketing (with consent): To send promotional offers, bonus notifications, and personalized recommendations where you have opted in to marketing communications. You may withdraw consent at any time via account settings.

3.2 All data processing activities are carried out on the legal bases of contractual necessity (to fulfill our obligations under the Terms & Conditions), legal compliance, legitimate business interests (fraud prevention, service improvement), and user consent (marketing communications).

4. Data Sharing & Disclosure

4.1 paca91 does not sell, rent, or trade your personal information to third parties for their own marketing purposes. We share your data only in the limited circumstances described below:

• Payment Processors: We share necessary financial data with licensed payment processors (banks, e-wallet providers) to facilitate deposits and withdrawals. These processors are bound by strict confidentiality and data protection obligations.
• KYC Verification Providers: We share identity documents with certified third-party KYC and age verification services to authenticate your identity and comply with regulatory requirements.
• Fraud Detection Services: We share transaction and behavioral data with specialized fraud detection and risk management providers to protect the platform and all users from fraudulent activity.
• Game Studios: Aggregate and anonymized gameplay data may be shared with our licensed game studio partners (Pragmatic Play, Evolution Gaming, etc.) for technical integration and product improvement purposes. Individual player identities are not disclosed.
• Legal and Regulatory Authorities: We may disclose personal data to law enforcement, regulatory bodies, courts, or other governmental authorities when required by law, court order, or regulatory request, or when necessary to protect our legal rights or the safety of others.
• Business Transfers: In the event of a merger, acquisition, reorganization, or sale of assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections outlined in this policy.

4.2 All third-party service providers with access to personal data are contractually bound to process data only in accordance with our instructions and to maintain equivalent levels of security and confidentiality.

5. Cookies & Tracking Technologies

5.1 paca91 uses cookies, web beacons, and similar tracking technologies to enhance user experience, analyze platform usage, and deliver personalized content. Cookies are small text files stored on your device that allow us to recognize your browser and remember certain information.

5.2 Types of Cookies We Use:

• Essential Cookies: Necessary for the platform to function. These cookies enable core features such as account login, session management, and secure access to your account area. These cookies cannot be disabled.
• Performance Cookies: Collect anonymous data on how users interact with the platform, including pages visited, error messages, and load times. This data is used to improve platform performance and user experience.
• Functional Cookies: Remember your preferences, such as language settings, display options, and betting slip configurations, to provide a more personalized experience.
• Marketing Cookies: Track your activity across the platform to deliver targeted promotional offers and measure the effectiveness of marketing campaigns. These cookies are only placed with your consent.

5.3 You can manage cookie preferences through your browser settings. However, disabling essential cookies may limit your ability to use certain features of the paca91 platform. For detailed instructions on managing cookies in popular browsers, visit your browser's help documentation.

6. Data Retention

6.1 paca91 retains personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy and to comply with legal, regulatory, and contractual obligations.

6.2 Active Accounts: Personal data associated with active accounts is retained for the duration of the account relationship plus a minimum of 7 years following account closure to comply with anti-money laundering regulations and to resolve any post-closure disputes.

6.3 Transaction Records: All financial transactions (deposits, withdrawals, bets, payouts) are retained for a minimum of 7 years from the date of the transaction for tax reporting, regulatory compliance, and audit purposes.

6.4 KYC Documents: Identity verification documents are retained for 7 years following account closure in accordance with AML regulations.

6.5 Marketing Data: If you withdraw consent to marketing communications, your contact details are retained on a suppression list to ensure we do not inadvertently contact you again, but no further marketing data is collected or processed.

6.6 At the end of the applicable retention period, personal data is securely deleted or anonymized such that it can no longer be associated with an identifiable individual.

7. Data Security

7.1 paca91 employs industry-standard physical, technical, and administrative security measures to protect personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS encryption. Sensitive data at rest (KYC documents, payment details) is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized paca91 personnel only, on a need-to-know basis. All personnel with data access undergo background checks and receive regular data protection training.
• Secure Infrastructure: Our servers are hosted in secure, ISO 27001-certified data centers with 24/7 physical security, redundant power supplies, and disaster recovery capabilities.
• Firewalls and Intrusion Detection: We employ enterprise-grade firewalls, intrusion detection systems, and continuous security monitoring to detect and prevent cyberattacks.
• Regular Audits: Our security practices are regularly audited by independent third-party security firms. Penetration testing is conducted quarterly to identify and remediate vulnerabilities.
• Password Protection: User passwords are hashed using bcrypt with per-user salts. We do not store passwords in plain text and cannot retrieve your password if forgotten (password reset only).

7.2 Despite our best efforts, no method of data transmission or storage is 100% secure. While we strive to protect your personal data, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for any activity that occurs under your account.

8. Your Data Rights

8.1 Indonesian residents and users in jurisdictions with applicable data protection laws have the following rights regarding their personal data:

• Right of Access: You have the right to request a copy of all personal data we hold about you. We will provide this data in a structured, commonly used, machine-readable format.
• Right of Rectification: If you believe any personal data we hold about you is inaccurate or incomplete, you have the right to request correction. You can update most information directly via your account settings.
• Right of Erasure: You have the right to request deletion of your personal data, subject to our legal and regulatory retention obligations (see Section 6). Active accounts cannot be deleted; you must first close your account.
• Right to Restrict Processing: You have the right to request that we restrict processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or object to processing.
• Right to Data Portability: You have the right to receive your personal data in a portable format and to request that we transfer it directly to another service provider where technically feasible.
• Right to Object: You have the right to object to processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests by providing specific reasons.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you have the right to withdraw consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

8.2 To exercise any of these rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Rights Request". We will respond to all requests within 30 days. Identity verification may be required to protect against fraudulent requests.

8.3 If you are not satisfied with our response to a data rights request or have concerns about how we handle your personal data, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.

9. International Data Transfers

9.1 paca91 is an internationally licensed platform, and your personal data may be transferred to and processed in countries outside of Indonesia, including jurisdictions where paca91's servers, third-party service providers, or business partners are located.

9.2 When we transfer personal data to countries that do not provide an equivalent level of data protection to Indonesian law, we implement appropriate safeguards including standard contractual clauses, binding corporate rules, and certification under recognized data protection frameworks.

9.3 By using the paca91 platform, you acknowledge and consent to the international transfer of your personal data as necessary to provide our services.

10. Children's Privacy

10.1 paca91 strictly prohibits use of the platform by anyone under the age of 21 years. We do not knowingly collect personal data from minors. Our registration process includes age verification, and all withdrawals require submission of government-issued ID confirming the user is 21 or older.

10.2 If we become aware that we have inadvertently collected personal data from a minor, we will immediately delete that data and permanently close the associated account. If you believe a minor has accessed the paca91 platform, please contact us immediately at [email protected].

11. Changes to This Privacy Policy

11.1 paca91 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or platform features. Where changes are material, we will provide at least 14 days' advance notice by posting a prominent notification on the platform and sending an email to the registered address associated with each active account.

11.2 The "Last Updated" date at the top of this document reflects the effective date of the most recent version. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.

11.3 Your continued use of the paca91 platform after the effective date of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree to the changes, you must cease using the platform and may request account closure.

12. Contact Us

12.1 If you have any questions, concerns, or requests regarding this Privacy Policy or how paca91 handles your personal data, you may contact us through the following channels:

• Email: [email protected] (plain text — not a clickable link; copy and paste into your mail client)
• Subject Line for Data Rights Requests: "Data Rights Request" or "Privacy Inquiry"
• Response Time: We aim to respond to all privacy inquiries within 72 hours and to formal data rights requests within 30 days.

12.2 For urgent security concerns (suspected account breach, unauthorized access), please contact us immediately via live chat available 24/7 on the platform.