Privacy Policy

1 Introduction & Scope

keno89 ("we", "us", "our", "the Platform") operates the online gaming website accessible at https://keno89.cam. This Privacy Policy applies to all personal data collected, processed, and stored by keno89 in connection with your use of the Platform, including account registration, identity verification, payment transactions, customer support interactions, and marketing communications.

This policy covers all members located in Indonesia and any other jurisdiction from which the Platform is legitimately accessed. It applies to data collected through the website, any associated mobile interface, and all direct communications channels including email and live chat. It does not cover the data practices of third-party service providers, whose own privacy policies govern their handling of any data shared with them pursuant to Section 6 of this policy.

keno89 acts as the data controller in respect of all personal data it collects directly from members. Where keno89 engages third-party processors — such as payment gateways, KYC verification providers, and analytics platforms — those entities act as data processors on keno89's behalf and are contractually bound to handle data only as directed by keno89 and in accordance with applicable data protection obligations.

2 Definitions

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person — including name, identification number, location data, or one or more factors specific to the physical, physiological, economic, or social identity of that person.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, combination, restriction, erasure, or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this context, keno89.
• "Data Processor" means an entity that processes Personal Data on behalf of, and under the instructions of, the Data Controller.
• "Consent" means a freely given, specific, informed, and unambiguous indication by which a data subject signifies agreement to the processing of their Personal Data.
• "KYC" means Know Your Customer — identity and address verification carried out to comply with anti-money laundering (AML) obligations and to confirm member eligibility.
• "Cookies" means small data files placed on a member's device by the Platform to enable functionality, measure performance, and support personalization.

3 Data We Collect

3.1 Data You Provide Directly

When you register an account, complete KYC, make a deposit or withdrawal, or contact customer support, keno89 collects the following categories of Personal Data:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification number (e.g., KTP number for Indonesian members).
• Contact Data: Indonesian mobile phone number and email address.
• Address Data: Residential address in Indonesia, including province, city (e.g., Jakarta, Surabaya, Medan, Bandung, Bali), and postal code.
• Financial Data: Bank account details (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, BSI) and e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja) necessary to process IDR deposits and withdrawals.
• KYC Documents: Scanned or photographed copies of identity documents (KTP, SIM, passport), proof of address, and selfie verification images submitted during the identity verification process.
• Support Communications: Records of your interactions with our customer support team, including live chat transcripts and email correspondence.

3.2 Data Collected Automatically

When you access the Platform, keno89 automatically collects certain technical and behavioral data:

• Device & Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and language settings.
• Usage Data: Pages visited, session duration, click patterns, game sessions played, bet amounts, and navigation paths within the Platform.
• Transaction Data: Deposit and withdrawal amounts, timestamps, payment method used, and transaction reference numbers — all denominated in Indonesian Rupiah (IDR / Rp).
• Cookie & Tracking Data: Session identifiers, preference cookies, and analytics tracking identifiers as further described in Section 7 of this policy.

3.3 Data from Third Parties

keno89 may receive supplementary Personal Data from third-party sources in the following circumstances:

• From KYC and identity verification providers who confirm the authenticity of documents and return a verification status alongside any flagged risk indicators.
• From payment processors and banking partners who confirm transaction success, failure, or chargeback status for IDR transfers made via local Indonesian banks and e-wallet networks.
• From fraud prevention and AML screening services that cross-reference member details against international sanctions lists and politically exposed person (PEP) databases.

4 How We Use Your Data

keno89 uses the Personal Data it collects for the following specific purposes:

• Account Management: To create, maintain, and administer your member account, including verifying your identity, managing your balance, and processing login authentication.
• Payment Processing: To execute IDR deposit and withdrawal transactions via your nominated Indonesian bank account (BCA, BRI, BNI, Mandiri, etc.) or e-wallet, and to maintain accurate transaction records.
• KYC & AML Compliance: To verify that you meet the eligibility requirements set out in our Terms & Conditions — including the requirement that all members be residents of Indonesia aged 21 or above — and to fulfill our obligations under applicable anti-money laundering frameworks.
• Customer Support: To respond to your queries, resolve disputes, process complaints, and deliver the service commitments described in our FAQ and Terms & Conditions.
• Responsible Gaming: To monitor account activity for signs of problem gambling, enforce self-exclusion requests, apply deposit and loss limits, and proactively reach out to members who may be experiencing gambling-related harm.
• Fraud Prevention & Platform Security: To detect, investigate, and prevent unauthorized account access, bonus abuse, multi-account registration, money laundering, and other prohibited conduct as defined in our Terms & Conditions.
• Platform Improvement: To analyze aggregated, anonymized usage data to improve game performance, optimize user experience, identify technical issues, and inform product development decisions.
• Marketing & Promotions: Where you have provided explicit consent, to send you personalized promotional offers, bonus notifications, and seasonal campaign communications relevant to events such as Idul Fitri, Ramadhan, and Indonesian Independence Day (17 August). You may withdraw consent at any time by contacting support.
• Legal & Regulatory Obligations: To comply with applicable laws, respond to lawful requests from regulatory or law enforcement authorities, and enforce our contractual rights.

5 Legal Basis for Processing

keno89 processes your Personal Data only where a valid legal basis exists. The primary legal bases on which keno89 relies are as follows:

• Contractual Necessity: Processing is necessary to perform the contract between keno89 and you as a registered member — including account registration, payment execution, KYC verification, and customer support. Without this processing, keno89 cannot deliver the services described in our Terms & Conditions.
• Legal Obligation: Processing is required to comply with applicable legal obligations, including AML regulations, identity verification mandates, and record-keeping requirements imposed by our international gaming licensing authority.
• Legitimate Interests: Processing is necessary for keno89's legitimate interests in operating a secure, fair, and commercially viable gaming platform — including fraud detection, platform security, responsible gaming monitoring, and platform analytics — provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: For marketing communications and non-essential cookies, keno89 processes your data on the basis of your freely given, informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Sharing Your Data

keno89 does not sell, rent, or trade your Personal Data. We share your data only in the following limited and controlled circumstances:

6.1 Service Providers & Data Processors

keno89 engages trusted third-party service providers who act as data processors and process Personal Data solely on our instructions. These include:

• KYC and identity verification platforms that validate member identity documents and return verification outcomes.
• Payment gateway operators that facilitate IDR transactions via Indonesian bank transfer and e-wallet networks.
• Cloud infrastructure and hosting providers responsible for the secure storage and operation of the keno89 Platform and its databases.
• Fraud detection and AML screening services that cross-check member data against financial crime databases.
• Customer support software providers that host our live chat and ticketing infrastructure.

All third-party processors are bound by contractual data processing agreements that prohibit the use of your Personal Data for any purpose beyond the specific service they perform for keno89.

6.2 Legal & Regulatory Disclosure

keno89 may disclose your Personal Data to governmental authorities, regulators, law enforcement bodies, or courts where required to do so by applicable law, court order, or regulatory requirement — including but not limited to AML reporting obligations and responses to lawful production orders. keno89 will notify affected members of such disclosures wherever legally permissible.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of keno89's business or assets, your Personal Data may be transferred to the acquiring or successor entity. In such circumstances, keno89 will use reasonable efforts to ensure that the receiving entity commits to handling your Personal Data in a manner consistent with this Privacy Policy, and will provide notice of any material change to data handling practices prior to the transfer taking effect.

7 Cookies & Tracking Technologies

7.1 What Are Cookies?

Cookies are small text files that are placed on your device when you visit the keno89 Platform. They allow the Platform to recognize your device, remember your preferences, maintain your login session, and measure how the site is used. keno89 uses a combination of first-party cookies (set by keno89 directly) and third-party cookies (set by trusted analytics and performance partners).

7.2 Types of Cookies Used

• Strictly Necessary Cookies: These cookies are essential for the Platform to function and cannot be disabled. They include session authentication tokens that keep you logged in, security cookies that protect against cross-site request forgery, and load-balancing cookies. No consent is required for these cookies as they are necessary for the delivery of the service.
• Functional Cookies: These cookies remember your preferences — such as your last-selected payment method and display language — to provide a more personalized experience. They can be disabled, but doing so may reduce platform functionality.
• Analytics Cookies: These cookies collect aggregated, anonymized data about how members navigate and interact with the Platform. This information is used solely to improve platform performance and user experience. These cookies are deployed only where you have provided consent.
• Marketing Cookies: Where you have consented to receive promotional communications, marketing cookies may be used to measure the effectiveness of campaigns and to ensure that promotional offers shown to you are relevant. keno89 does not use retargeting pixels that track your activity on external, third-party websites.

7.3 Managing Your Cookie Preferences

You may manage your cookie preferences at any time through your browser settings. Most modern browsers allow you to view, block, or delete cookies via their privacy or security settings menus. Note that blocking strictly necessary cookies will impair your ability to use the Platform. To withdraw consent for analytics or marketing cookies previously granted, contact support at [email protected].

8 Data Security

keno89 implements a multi-layered security framework designed to protect your Personal Data against unauthorized access, disclosure, alteration, or destruction. The principal measures in place include:

• 256-Bit SSL/TLS Encryption: All data transmitted between your device and keno89's servers is encrypted using industry-standard Transport Layer Security (TLS). No Personal Data is transmitted in plain text under any circumstances.
• Encryption at Rest: Sensitive Personal Data stored in keno89's databases — including identity document images, financial account references, and KYC records — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to Personal Data within keno89's internal systems is restricted on a strict need-to-know basis. Staff with access to member data undergo background screening and are bound by confidentiality obligations. Access logs are maintained and audited regularly.
• Two-Factor Authentication (2FA): Internal administrative systems that provide access to member data require mandatory two-factor authentication for all personnel.
• Penetration Testing & Vulnerability Management: keno89's infrastructure is subject to regular independent penetration testing and continuous automated vulnerability scanning. Identified vulnerabilities are remediated on a risk-prioritized basis.
• Incident Response: keno89 maintains a documented data breach response plan. In the event of a breach that creates a risk to member rights and freedoms, affected members will be notified without undue delay and in accordance with applicable regulatory requirements.

9 Data Retention

keno89 retains your Personal Data only for as long as necessary to fulfill the purposes for which it was collected, subject to any longer retention period required by applicable law or regulatory obligation. The key retention periods are as follows:

• Active Account Data: Personal Data associated with an active member account is retained for the duration of the account's active status and for a minimum of five (5) years following account closure, in accordance with standard AML record-keeping obligations.
• KYC Documents: Identity documents submitted for verification are retained for a minimum of five (5) years from the date of submission or from the date of account closure, whichever is later, as required under applicable anti-money laundering regulations.
• Transaction Records: Records of deposits, withdrawals, and bet history are retained for a minimum of five (5) years to satisfy financial record-keeping and audit obligations.
• Customer Support Records: Live chat transcripts and email correspondence are retained for a period of two (2) years from the date of the interaction, unless a longer period is required in connection with an ongoing dispute or regulatory inquiry.
• Marketing Consent Records: Records of your consent to receive marketing communications are retained for as long as marketing is active plus an additional period to demonstrate the lawfulness of past processing, and are deleted within ninety (90) days of consent withdrawal.
• Technical & Analytics Data: Anonymized or aggregated usage and analytics data, which can no longer be linked to any identifiable individual, may be retained indefinitely for platform improvement purposes.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymized using industry-standard data destruction methods. Where anonymization is not technically feasible, data is pseudonymized and access-restricted pending scheduled deletion.

10 Your Rights

As a data subject, you hold the following rights in relation to your Personal Data held by keno89. keno89 is committed to facilitating the exercise of these rights promptly and without undue restriction:

• Right of Access: You have the right to request a copy of all Personal Data keno89 holds about you, along with information about how it is used and with whom it is shared.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete Personal Data. For certain data fields (name, date of birth), rectification may require submission of supporting documentation through the KYC process.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent and no other legal basis applies, or where processing is unlawful. Note that this right is subject to override by keno89's legal retention obligations, particularly in respect of AML and financial record-keeping requirements.
• Right to Restriction of Processing: You may request that keno89 temporarily restrict the processing of your Personal Data — for example, while a rectification request is under review or where you have contested the lawfulness of processing.
• Right to Data Portability: Where processing is based on consent or contractual necessity, you have the right to receive your Personal Data in a structured, commonly used, machine-readable format, and to request that keno89 transmit that data to another controller where technically feasible.
• Right to Object: You have the right to object to processing based on legitimate interests, including profiling for responsible gaming purposes. keno89 will cease such processing unless it can demonstrate compelling legitimate grounds that override your rights, or where processing is necessary for the establishment or defense of legal claims.
• Right to Withdraw Consent: Where processing is based on your consent — specifically for marketing communications and non-essential cookies — you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing that occurred prior to withdrawal.

To exercise any of the above rights, submit a written request to [email protected] with the subject line "Data Subject Request" and include sufficient information to verify your identity. keno89 will acknowledge your request within five (5) business days and will provide a substantive response within thirty (30) calendar days, extendable by a further thirty (30) days for complex requests.

11 International Data Transfers

keno89 operates a globally distributed infrastructure to maintain platform performance and resilience for members across Indonesia — from Jakarta and Surabaya to Medan, Bandung, Bali, Yogyakarta, Makassar, and beyond. As a result, your Personal Data may be stored on or processed by servers located outside Indonesia.

Where Personal Data is transferred to jurisdictions that may not provide an equivalent level of data protection to that available under applicable Indonesian law, keno89 implements appropriate safeguards to ensure your data remains protected to a standard consistent with this Privacy Policy. These safeguards include:

• Contractual clauses binding the receiving entity to data protection standards equivalent to those applied by keno89.
• Transfers only to jurisdictions or entities that have received an adequacy determination or equivalent certification recognized by keno89's licensing authority.
• End-to-end encryption for all data in transit, regardless of the geographic route taken.

For further information about the specific safeguards in place for international transfers of your data, contact [email protected].

12 Minors & Age Policy

The keno89 Platform is strictly intended for adults aged 21 years and above. keno89 does not knowingly collect Personal Data from any individual under the age of 21. The 21+ minimum age is verified through the mandatory KYC process, which requires all members to submit a government-issued identity document confirming date of birth.

If keno89 discovers that Personal Data has been collected from a person under the age of 21 — whether through misrepresentation at registration or any other means — the following actions will be taken immediately:

• The relevant account will be suspended and then permanently closed.
• All funds in the account will be handled in accordance with keno89's underage gambling policy, which may involve forfeiture of winnings and return of verifiable deposits to the source payment method.
• All Personal Data associated with the account will be permanently deleted as soon as legally permissible, subject to any obligation to retain records for AML or fraud investigation purposes.

13 Amendments to This Policy

keno89 reserves the right to update or revise this Privacy Policy at any time in response to changes in applicable law, regulatory guidance, our data processing activities, or the services we offer. Material amendments — meaning changes that substantively affect how your Personal Data is collected, used, or shared — will be communicated to registered members via email and/or a prominent notice on the Platform, no fewer than fourteen (14) calendar days before they take effect.

Minor amendments — such as typographical corrections, clarifications that do not alter substantive meaning, or updates to contact details — may be made without advance notice, with the updated effective date reflected at the top of this page.

Your continued use of the keno89 Platform after the effective date of any amendment constitutes your acknowledgment of and agreement to the revised Privacy Policy. If you do not agree to the revised terms, you should cease using the Platform and request account closure before the effective date of the amendment. A copy of the previous version of this policy may be requested by contacting support.

14 Contact & Data Controller

keno89 is the data controller in respect of all Personal Data collected through the Platform. If you have any questions, concerns, or complaints relating to this Privacy Policy or to the handling of your Personal Data, please contact our Data Protection team through the following channel:

• Email: [email protected] — please use the subject line "Privacy Policy Enquiry" or "Data Subject Request" as appropriate.
• Live Chat: Available 24 hours a day, 7 days a week via the live chat widget on the Platform. For data-related matters, live chat agents will escalate your query to the Data Protection team within one (1) business day.
• Response Commitment: keno89 commits to acknowledging all Privacy Policy enquiries within two (2) business days and to providing a substantive response within ten (10) business days.

For responsible gaming concerns, please visit our dedicated Responsible Gaming page. For questions about account terms, deposits, or withdrawals, visit our FAQ page or review our Terms & Conditions.

This Privacy Policy was last reviewed and updated on 1 January 2026. keno89 is a registered trademark. All rights reserved.