Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how ubo365 ("we", "us", "our", "Company") collects, uses, discloses, stores, and safeguards personal information provided by users ("you", "your", "User", "Member") when accessing or using the ubo365 online gaming platform at https://ubo365.cam (the "Service" or "Platform").

ubo365 is committed to protecting the privacy and security of our members' personal data. We operate in the Indonesian market and understand that trust is fundamental to our relationship with every player in Jakarta, Surabaya, Medan, Bandung, Yogyakarta, and across the archipelago. This Policy is written in plain, accessible English so that every member can understand exactly how their information is handled.

By creating an account, accessing the Platform, or using any Service provided by ubo365, you consent to the data practices described in this Policy. If you do not agree with any part of this Policy, please do not use the Platform. This Policy is incorporated by reference into our Terms & Conditions and should be read alongside that document.

2. Definitions

For clarity, the following definitions apply throughout this Policy:

• Personal Data: Any information that identifies or can reasonably be used to identify a living individual, including name, date of birth, national identity number, address, email address, phone number, IP address, and payment details.
• Sensitive Personal Data: A subset of personal data requiring heightened protection, including government-issued identity documents (KTP), financial account details, and biometric data collected during identity verification.
• Processing: Any operation performed on personal data, including collection, storage, use, disclosure, alteration, and deletion.
• Data Controller: The entity that determines the purposes and means of processing personal data. For this Policy, the data controller is ubo365.
• Third Party: Any individual, company, or entity other than you or ubo365.
• Cookie: A small text file stored on your device by your web browser when you visit a website, used to recognize returning visitors and store preferences.
• KYC: Know Your Customer — the identity verification process required to confirm your name, age, and residency before full account access is granted.

3. Information We Collect

3.1 Information You Provide Directly

When you register, verify your account, use the Service, or contact customer support, ubo365 collects information you provide directly, including:

• Registration Data: Full legal name, date of birth, Indonesian residential address, email address, and mobile phone number.
• Identity Verification Documents: Copies of your KTP (Kartu Tanda Penduduk / Indonesian National Identity Card) or passport, proof of address documents, and selfie photographs taken as part of the KYC verification process.
• Financial Information: Bank account details (BCA, BRI, BNI, Mandiri, CIMB Niaga) and e-wallet identifiers (OVO, DANA, GoPay, ShopeePay) used for deposits and withdrawals. We do not store full bank account passwords or full card numbers.
• Communications: The content of messages you send to our customer support team via live chat, email, or in-app messaging, including queries, complaints, and feedback.
• Responsible Gaming Preferences: Self-imposed limits, cool-off preferences, and self-exclusion requests you configure in your account settings.

3.2 Information Collected Automatically

When you access the Platform, certain information is collected automatically by our systems:

• Device and Technical Data: IP address, browser type and version, operating system, device type (desktop, mobile, tablet), screen resolution, and timezone.
• Usage Data: Pages visited, features used, games played, session duration, betting and wagering activity, deposit and withdrawal history, and click-stream data.
• Cookies and Tracking Technologies: Session cookies (required for login functionality), preference cookies (to remember your settings), and analytics cookies (to understand how users interact with the Platform). See Section 9 for full details on our cookie practices.
• Fraud Prevention Data: Device fingerprinting, login location, unusual activity patterns, and other signals used by our fraud detection systems to protect your account and the integrity of the Platform.

3.3 Information from Third Parties

We may receive information about you from trusted third parties including identity verification services (used to cross-reference KYC documents), payment processors (transaction confirmation and fraud signals), and analytics providers (aggregated, anonymized usage insights). We do not purchase personal data lists or obtain your data from social media platforms without your explicit consent.

4. How We Use Your Information

ubo365 uses the personal data we collect for the following clearly defined purposes:

• Account Management: To create and maintain your account, verify your identity and age (21+ requirement), process KYC documentation, and manage your account preferences and settings.
• Service Delivery: To process deposits and withdrawals through your chosen Indonesian banking or e-wallet provider, deliver game content, record and display betting history, and calculate and credit winnings accurately.
• Security and Fraud Prevention: To monitor for unauthorized access, detect fraudulent activity, enforce our Terms & Conditions, prevent multi-accounting and bonus abuse, and protect the financial integrity of the Platform.
• Responsible Gaming: To monitor for patterns associated with problem gambling, enforce self-imposed limits you have set, process self-exclusion requests, and comply with our responsible gaming obligations.
• Customer Support: To respond to your queries, resolve disputes, provide technical assistance, and improve the quality of our support services based on interaction history.
• Legal Compliance: To comply with applicable anti-money laundering (AML) regulations, respond to lawful requests from regulatory authorities, and maintain financial transaction records as required by law.
• Platform Improvement: To analyze usage patterns, diagnose technical issues, improve game performance, and develop new features that better serve Indonesian players.
• Marketing Communications: To send you information about promotions, bonuses, and platform updates — but only if you have opted in to receive marketing communications. You may withdraw consent at any time.

5. Legal Basis for Processing

ubo365 processes your personal data on the following legal grounds:

• Contractual Necessity: Processing required to fulfill our obligations under the Terms & Conditions you agreed to, including account creation, payment processing, and service delivery.
• Legal Obligation: Processing necessary to comply with applicable laws, including anti-money laundering regulations, KYC requirements, and financial record-keeping obligations.
• Legitimate Interests: Processing for fraud prevention, security monitoring, and platform improvement, where our legitimate business interests do not override your fundamental rights and freedoms.
• Consent: Processing for marketing communications and non-essential cookies, where you have given explicit, informed consent that you may withdraw at any time without penalty to your account.

6. Data Sharing and Disclosure

ubo365 does not sell your personal data to any third party. We share data only in the following strictly defined circumstances:

• Service Providers: Trusted third-party vendors who assist us in operating the Platform, including payment processors (for deposit and withdrawal handling), identity verification services (for KYC processing), cloud infrastructure providers, and customer support software providers. All service providers are bound by data processing agreements that prohibit them from using your data for any purpose other than the specific service they provide to us.
• Game Providers: Licensed game studios whose titles are offered on the Platform may receive anonymized game session data for performance monitoring and fairness auditing. No personally identifiable information is shared with game studios.
• Legal and Regulatory Authorities: We will disclose personal data to law enforcement agencies, regulatory authorities, or courts when required to do so by applicable law or in response to a valid legal process. We will notify you of such disclosures where legally permissible.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of ubo365's assets, your personal data may be transferred to the successor entity. We will notify you before your data is transferred and becomes subject to a different privacy policy.

Under no circumstances do we share your personal data with third-party advertisers, data brokers, or any entity for commercial marketing purposes without your explicit prior consent.

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, subject to the following retention standards:

• Active Account Data: Retained for the lifetime of your account and for a period of five years after account closure, to comply with AML regulations and facilitate dispute resolution.
• Financial Transaction Records: Retained for a minimum of five years from the date of each transaction as required by anti-money laundering and financial compliance regulations.
• KYC Documents: Retained for five years from account closure or from the date of the last transaction, whichever is later.
• Customer Support Communications: Retained for three years from the date of the interaction, unless the communication relates to an ongoing dispute, in which case it is retained until the dispute is fully resolved.
• Marketing Consent Records: Retained for the duration of your marketing subscription plus three years after you unsubscribe, to demonstrate compliance with consent requirements.
• Analytics Data: Aggregated, anonymized analytics data with no personally identifiable information may be retained indefinitely for platform improvement purposes.

8. Data Security Measures

ubo365 implements a comprehensive range of technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction:

• Encryption: All data in transit is protected by TLS 1.2 or higher (HTTPS). Personal data and financial information stored on our servers is encrypted at rest using AES-256 encryption.
• Access Controls: Internal access to personal data is restricted on a strict need-to-know basis. All staff with data access undergo background checks and receive regular data protection training.
• Infrastructure Security: Our servers are hosted in secure data centers with physical access controls, redundant systems, and regular security audits. We use firewalls, intrusion detection systems, and regular penetration testing to identify and address vulnerabilities.
• Password Security: User passwords are stored as one-way cryptographic hashes (bcrypt). We never store plaintext passwords and cannot retrieve your password — only reset it.
• Fraud Detection: Automated and manual monitoring systems flag unusual account activity patterns for review, protecting your account from unauthorized access and fraudulent transactions.

Despite our best efforts, no security system is completely impenetrable. If you discover a potential security vulnerability in our Platform, please report it responsibly to [email protected]. In the event of a security breach affecting your data, we will notify you promptly in accordance with our breach notification obligations.

9. Cookies and Tracking Technologies

ubo365 uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and analyze usage patterns. The following cookie categories are used:

• Essential Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in and security tokens that protect against cross-site request forgery attacks. These cannot be disabled.
• Functional Cookies: Remember your preferences such as chosen language, last visited game category, and responsible gaming settings. Disabling these may affect your user experience.
• Analytics Cookies: Collect anonymized, aggregated information about how users navigate the Platform, which pages are most visited, and where users encounter difficulties. Used to improve the Platform experience.

You can manage non-essential cookies through your browser settings. Please note that disabling certain cookies may impair Platform functionality. We do not use third-party advertising cookies or behavioral tracking cookies for targeted advertising.

10. Your Privacy Rights

As a ubo365 member, you have the following rights in relation to your personal data:

• Right of Access: Request a copy of all personal data we hold about you, along with information about how it is used and shared.
• Right to Rectification: Request correction of inaccurate or incomplete personal data held on your account.
• Right to Erasure: Request deletion of your personal data, subject to our legal retention obligations (we cannot delete financial records we are legally required to retain).
• Right to Data Portability: Request your personal data in a structured, machine-readable format for transfer to another service provider.
• Right to Withdraw Consent: Withdraw consent for marketing communications or non-essential cookies at any time without affecting the lawfulness of processing that occurred before withdrawal.
• Right to Restrict Processing: Request that we limit the way we use your personal data in certain circumstances, such as while a complaint is being investigated.

To exercise any of these rights, contact our support team at [email protected]. We will respond to all verified requests within 30 days. We may need to verify your identity before processing your request to protect against unauthorized access to your data.

11. Minors and Age Restrictions

ubo365 strictly prohibits the use of our Platform by any individual under the age of 21. We do not knowingly collect personal data from persons under 21 years of age. All accounts must be verified through our KYC process, which includes confirming date of birth against government-issued identification.

If we discover that we have inadvertently collected personal data from a person under 21, we will immediately close the account, refund any deposits, and delete all associated personal data. Parents or guardians who believe their child has created an account should contact us immediately at [email protected].

12. Changes to This Privacy Policy

ubo365 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or Platform features. When we make material changes, we will notify you by email (to the address registered to your account) and by displaying a prominent notice on the Platform for at least 30 days before changes take effect.

We encourage you to review this Policy periodically to stay informed about how we protect your information. The date of the most recent revision is clearly displayed at the top of this page. Your continued use of the Platform after changes take effect constitutes acceptance of the revised Policy.

13. Contact and Data Enquiries

If you have any questions, concerns, or requests relating to this Privacy Policy or how ubo365 handles your personal data, please contact us through the following channel:

Email: [email protected]
Response Time: Within 4 hours during normal hours; within 24 hours at all other times
Availability: 24 hours a day, 7 days a week

Please include "Privacy Request" or "Data Enquiry" in the subject line of your email so our team can route your query to the appropriate person promptly. All privacy-related requests are handled with strict confidentiality.