Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal data collected by 9koi through the website located at https://9koi.cam, mobile applications, customer support interactions, and any other channels through which you interact with our services. By creating an account or using any 9koi 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.

9koi is committed to transparency in data handling practices. This Privacy Policy is designed to help you understand what information we collect, why we collect it, how we use it, and what choices you have regarding your personal data. We encourage you to read this policy carefully and contact our Data Protection Officer if you have any questions or concerns about how your information is handled.

This Privacy Policy should be read in conjunction with our Terms and Conditions and Responsible Gaming Policy, which together form the complete legal framework governing your use of the 9koi platform. In the event of any conflict between this Privacy Policy and other policies, the more privacy-protective provision shall apply.

2. Information We Collect

2.1 Personal Identification Information

When you register for a 9koi account, we collect personal identification information necessary to verify your identity, comply with legal requirements, and provide our services. This includes your full legal name as it appears on government-issued identification documents, date of birth to verify you meet the minimum age requirement of 21 years, residential address in Indonesia, valid email address, mobile phone number registered in Indonesia, and preferred username and password for account access.

2.2 Verification Documents

As part of our Know Your Customer (KYC) and anti-money laundering compliance procedures, 9koi requires users to submit verification documents. These may include a clear photograph or scan of your Indonesian KTP (Kartu Tanda Penduduk) or other government-issued photo identification showing your name, photograph, date of birth, and document number; proof of address such as a utility bill, bank statement, or official government correspondence dated within the last three months; and a selfie photograph holding your identification document next to your face for identity verification purposes.

2.3 Financial Information

To process deposits and withdrawals, 9koi collects financial information including bank account details (bank name, account number, account holder name) for Indonesian banks such as BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, and Bank Permata; e-wallet account information for OVO, DANA, GoPay, ShopeePay, and LinkAja; transaction history including deposit amounts, withdrawal amounts, dates, and payment methods; and betting history including wagers placed, games played, wins, losses, and account balance changes.

2.4 Technical and Usage Data

9koi automatically collects certain technical and usage information when you access our platform. This includes IP address and geographic location data to verify you are accessing the platform from within Indonesia; device information including device type, operating system, browser type and version, and screen resolution; access logs showing login times, pages viewed, features used, and session duration; cookie data and unique identifiers for authentication, preference storage, and analytics; and gameplay data including games played, bet amounts, game outcomes, and playing patterns.

2.5 Communications and Support Data

When you contact 9koi customer support or communicate with us through any channel, we collect and store records of your communications including live chat transcripts, email correspondence, WhatsApp messages, phone call recordings (with notice), support ticket details and resolution history, and feedback, complaints, or inquiries submitted through any channel.

3. How We Use Your Information

9koi uses the personal information we collect for the following specific purposes:

3.1 Account Management and Service Provision

• Creating and maintaining your user account on the 9koi platform
• Verifying your identity and age to ensure compliance with legal requirements
• Processing deposits, withdrawals, and other financial transactions
• Providing access to casino games, sports betting, togel, sabung ayam, and other gaming services
• Maintaining your betting history, account balance, and transaction records
• Administering bonuses, promotions, and loyalty programs
• Responding to your inquiries, support requests, and complaints

3.2 Legal and Regulatory Compliance

• Complying with Know Your Customer (KYC) and anti-money laundering (AML) regulations
• Preventing underage gambling and verifying users meet the 21+ age requirement
• Detecting and preventing fraud, money laundering, and other illegal activities
• Responding to legal requests from law enforcement or regulatory authorities
• Maintaining records required by applicable gambling regulations and licensing requirements
• Conducting internal audits and investigations when necessary

3.3 Platform Security and Fraud Prevention

• Monitoring account activity for suspicious patterns or potential fraud
• Detecting and preventing multiple account abuse and bonus abuse
• Identifying and blocking accounts engaged in cheating or unfair practices
• Protecting against unauthorized access, hacking attempts, and cyber attacks
• Verifying the legitimacy of withdrawal requests and preventing unauthorized transactions
• Investigating disputes, chargebacks, and payment issues

3.4 Responsible Gaming and Player Protection

• Implementing and enforcing deposit limits, loss limits, and session time limits set by users
• Monitoring gameplay patterns for signs of problem gambling behavior
• Processing self-exclusion requests and cooling-off period activations
• Providing reality check reminders and responsible gaming tool notifications
• Connecting users with problem gambling resources and support services when appropriate

3.5 Platform Improvement and Analytics

• Analyzing user behavior and preferences to improve platform functionality and user experience
• Testing new features, games, and services before full release
• Generating aggregated, anonymized statistics about platform usage and performance
• Optimizing website performance, load times, and mobile responsiveness
• Personalizing your experience based on game preferences and playing history

3.6 Marketing and Communications (With Consent)

• Sending promotional emails about bonuses, new games, and special offers (opt-in only)
• Providing personalized bonus offers based on your gaming preferences and history
• Notifying you about important account updates, policy changes, and service announcements
• Conducting customer satisfaction surveys and requesting feedback (optional participation)

4. Legal Basis for Data Processing

9koi processes your personal data on the following legal bases:

4.1 Contractual Necessity

Processing is necessary to perform the contract between you and 9koi, specifically to provide gaming services, process financial transactions, maintain your account, and fulfill our obligations under the Terms and Conditions. Without processing this data, we cannot provide our services to you.

4.2 Legal Obligation

Processing is necessary to comply with legal obligations imposed on 9koi by Indonesian law, international gambling regulations, anti-money laundering legislation, tax laws, and licensing requirements. This includes mandatory identity verification, transaction monitoring, record retention, and reporting to regulatory authorities.

4.3 Legitimate Interests

Processing is necessary for legitimate interests pursued by 9koi, provided these interests are not overridden by your fundamental rights and freedoms. Legitimate interests include fraud prevention and detection, platform security, preventing underage gambling, investigating suspected Terms violations, improving services, and protecting against legal liability. We conduct regular assessments to ensure our legitimate interests remain balanced against your privacy rights.

4.4 Consent

For certain processing activities, particularly marketing communications and non-essential cookies, we rely on your explicit consent. You have the right to withdraw consent at any time, which will not affect the lawfulness of processing based on consent before withdrawal. Withdrawing consent does not affect other legal bases for processing your data.

5. Data Sharing and Disclosure

9koi does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information in the following limited circumstances:

5.1 Service Providers and Business Partners

We share data with trusted third-party service providers who perform functions on our behalf, including payment processors handling deposits and withdrawals through Indonesian banks and e-wallets; game providers supplying casino games, slots, live dealer games, and sports betting platforms; identity verification services conducting KYC checks and document authentication; cloud hosting providers storing data on secure servers; customer support platforms managing live chat, ticketing, and communication tools; and analytics providers helping us understand platform usage and user behavior. All service providers are contractually obligated to protect your data and use it only for the specified purposes. We conduct due diligence on all third parties before sharing data.

5.2 Legal and Regulatory Requirements

We may disclose your information when required by law or when we believe disclosure is necessary to comply with legal processes, such as court orders or subpoenas; enforce our Terms and Conditions and other agreements; protect the rights, property, or safety of 9koi, our users, or others; prevent or investigate fraud, security issues, or technical problems; or respond to requests from government authorities, law enforcement, or regulatory bodies.

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy involving 9koi, 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, and you will have choices regarding your data in such circumstances.

5.4 Aggregated and Anonymized Data

We may share aggregated, anonymized data that cannot be used to identify you individually with business partners, advertisers, or the public for industry analysis, demographic profiling, marketing, or other purposes. This data does not contain any personally identifiable information.

6. Data Security Measures

9koi employs comprehensive technical and organizational security measures to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction:

6.1 Technical Security Controls

• SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using bank-level SSL/TLS protocols, ensuring data cannot be intercepted during transmission.
• Data Encryption at Rest: Personal information stored on our servers is encrypted using industry-standard encryption algorithms, protecting data even if physical servers are compromised.
• Secure Servers: Data is stored on secure servers located in protected data centers with physical security controls including biometric access, 24/7 surveillance, and environmental protections.
• Firewall Protection: Multi-layered firewall systems protect our infrastructure from external threats, intrusion attempts, and denial-of-service attacks.
• Intrusion Detection: Real-time monitoring systems detect and respond to suspicious activity, unauthorized access attempts, and potential security breaches.
• Regular Security Audits: Independent security firms conduct regular penetration testing and vulnerability assessments to identify and address potential weaknesses.

6.2 Organizational Security Measures

• Access Controls: Access to personal data is restricted on a need-to-know basis, with employees granted access only to information necessary for their job functions.
• Staff Training: All employees receive regular training on data protection, privacy regulations, security protocols, and confidentiality obligations.
• Confidentiality Agreements: Employees and contractors sign confidentiality agreements prohibiting unauthorized disclosure of user information.
• Incident Response Plan: We maintain a documented incident response plan for identifying, containing, and resolving security breaches or data incidents.
• Data Minimization: We regularly review and delete data that is no longer necessary for the purposes for which it was collected.

6.3 User Security Responsibilities

While 9koi implements robust security measures, you also play a critical role in protecting your account. You should use a strong, unique password combining uppercase and lowercase letters, numbers, and special characters; never share your login credentials with anyone; log out of your account when using shared or public computers; keep your email account secure, as it is used for password reset and account communications; enable two-factor authentication if offered; and immediately notify customer support if you suspect unauthorized account access.

7. Cookies and Tracking Technologies

9koi uses cookies, web beacons, and similar tracking technologies to enhance your experience, analyze platform usage, and improve our services.

7.1 Types of Cookies We Use

Cookie Type	Purpose	Duration
Essential Cookies	Required for basic platform functionality, authentication, and security. Cannot be disabled.	Session or up to 12 months
Performance Cookies	Collect anonymized data about how visitors use the site to improve performance and user experience.	Up to 24 months
Functionality Cookies	Remember your preferences, language settings, and customization choices.	Up to 12 months
Analytics Cookies	Help us understand user behavior, popular features, and areas for improvement.	Up to 24 months
Marketing Cookies	Used to deliver relevant promotional content and measure campaign effectiveness (with consent).	Up to 12 months

7.2 Managing Cookie Preferences

You can control cookie settings through your browser preferences. Most browsers allow you to refuse cookies, delete existing cookies, or receive notifications when new cookies are set. However, disabling certain cookies may affect platform functionality, including login capability, game loading, and preference retention. Essential cookies cannot be disabled as they are necessary for platform operation and security.

8. Data Retention

9koi retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy and comply with legal obligations.

8.1 Active Account Data Retention

Personal information in active accounts is retained for the duration of the account's active status plus any period required by law or regulation. This includes all data necessary to provide services, maintain account history, and comply with legal requirements.

8.2 Closed Account Data Retention

After account closure, 9koi retains certain information for the following periods: identity verification documents and KYC records are retained for 7 years from account closure to comply with anti-money laundering regulations; financial transaction records including deposits, withdrawals, and betting history are retained for 7 years for tax and regulatory compliance; communications and support records are retained for 3 years for dispute resolution purposes; and marketing preferences and consent records are retained for 3 years to honor opt-out requests.

8.3 Legal Hold and Investigation Data

Data related to ongoing investigations, disputes, litigation, or regulatory inquiries is retained for the duration of the matter plus applicable statute of limitations periods, regardless of account closure or standard retention schedules. This ensures 9koi can defend its rights and comply with legal obligations.

8.4 Anonymized Data

After applicable retention periods expire, personal data is either securely deleted or anonymized. Anonymized data that cannot be linked back to you may be retained indefinitely for statistical analysis, research, and business intelligence purposes.

9. Your Privacy Rights

Under applicable data protection laws, you have the following rights regarding your personal information:

9.1 Right of Access

You have the right to request confirmation of whether 9koi processes your personal data and to receive a copy of that data. You can request access to your account information, transaction history, verification documents, communications records, and any other personal data we hold about you. Access requests will be fulfilled within 30 days.

9.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You can update most account information directly through your account settings. For changes to verified information such as name or date of birth, contact customer support with supporting documentation.

9.3 Right to Erasure (Right to be Forgotten)

You have the right to request deletion of your personal data in certain circumstances, including when the data is no longer necessary for the purposes for which it was collected, when you withdraw consent for consent-based processing, or when you object to processing based on legitimate interests. However, 9koi may retain data where required by law, necessary for legal claims, or needed to protect against fraud.

9.4 Right to Restriction of Processing

You have the right to request that 9koi restrict processing of your personal data in specific situations, such as while disputes about accuracy or lawfulness are being resolved. Restricted data will be stored but not actively processed except with your consent or for legal claims.

9.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit that data to another service provider where technically feasible. This applies to data you provided to 9koi and that we process based on consent or contractual necessity.

9.6 Right to Object

You have the right to object to processing of your personal data based on legitimate interests, including profiling and direct marketing. Upon receiving an objection to marketing, 9koi will immediately cease such processing. For objections based on legitimate interests, we will cease processing unless we demonstrate compelling legitimate grounds that override your rights.

9.7 Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted before withdrawal. To withdraw consent for marketing communications, use the unsubscribe link in emails or contact customer support.

9.8 Exercising Your Rights

To exercise any of these rights, contact our Data Protection Officer at [email protected] (display as plain text). Include your full name, registered email address, account username, and specific right you wish to exercise. We may request additional information to verify your identity before processing the request. There is no charge for exercising these rights unless requests are manifestly unfounded or excessive.

10. Children's Privacy

9koi services are strictly restricted to individuals aged 21 years or older. We do not knowingly collect personal information from anyone under 21 years of age. Our age verification procedures are designed to prevent underage access. If we become aware that personal information has been collected from someone under 21, we will immediately delete that information, close the associated account, and forfeit any remaining balance. Parents or guardians who believe their child under 21 has provided information to 9koi should contact customer support immediately.

11. International Data Transfers

Your personal information may be transferred to and processed in countries outside Indonesia where 9koi, its service providers, or business partners operate. These countries may have data protection laws that differ from Indonesian law. When transferring data internationally, 9koi ensures appropriate safeguards are in place, including Standard Contractual Clauses approved by data protection authorities, Privacy Shield certification for transfers to certified organizations, and binding corporate rules for transfers within corporate groups. We ensure all international data transfers comply with applicable data protection regulations and maintain the same level of protection required under Indonesian law.

12. Changes to This Privacy Policy

9koi reserves the right to modify, amend, or update this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or business operations. When material changes are made, we will notify you through prominent notice on the website, email notification to your registered email address, or in-app notification when you next log in. The "Last Updated" date at the top of this policy indicates when the most recent changes were made. Your continued use of 9koi services after notification of changes constitutes acceptance of the updated Privacy Policy. We encourage you to review this policy periodically to stay informed about how we protect your information.

13. Contact Information and Complaints

If you have questions, concerns, or complaints about this Privacy Policy or our data handling practices, please contact our Data Protection Officer:

• Email: [email protected] (display as plain text only - not a clickable link)
• Subject Line: "Privacy Inquiry" or "Data Protection Request"
• Response Time: We aim to respond to all privacy inquiries within 7 business days

If you are not satisfied with our response or believe we are processing your data unlawfully, you have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction. We would, however, appreciate the opportunity to address your concerns before you approach the supervisory authority, so please contact us first.