Privacy Policy

1. Introduction and Scope

This Privacy Policy governs the collection, use, storage, and protection of personal information by tepe78 (referred to as "we", "us", "our") when you access or use our website at https://tepe78.cam (the "Platform") and related services (collectively, the "Services"). This Privacy Policy applies to all users, including visitors who browse the Platform without registering and registered players who create accounts and use our betting and gaming services.

By accessing the tepe78 Platform or using our Services, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your personal information as described in this Privacy Policy. If you do not agree with this Privacy Policy, you must discontinue use of the Platform and Services immediately. This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern your use of tepe78 Services.

2. Information We Collect

tepe78 collects various types of personal and non-personal information to provide, maintain, improve, and secure our Services. The information we collect falls into the following categories:

2.1 Information You Provide Directly

When you register for a tepe78 account, we collect personal information that you voluntarily provide, including:

• Identity Information: Full legal name (as it appears on your Indonesian identity document), date of birth, gender, nationality
• Contact Information: Email address, mobile phone number, residential address (street, city, province, postal code)
• Account Credentials: Username, password (stored in encrypted form), security questions and answers
• Identity Verification Documents (KYC): Copies of Indonesian identity card (KTP), proof of address (utility bills, bank statements), selfie photographs holding identity documents, and any additional documents requested for enhanced due diligence
• Financial Information: Bank account details (bank name, account number, account holder name), e-wallet account information (OVO, DANA, GoPay account names), cryptocurrency wallet addresses
• Communication Data: Any information you provide when contacting customer support via live chat, email, phone, or WhatsApp, including the content of your messages, support tickets, and complaint details
• Marketing Preferences: Your communication preferences, subscription choices for promotional emails, SMS, and push notifications

2.2 Information We Collect Automatically

When you access and use the tepe78 Platform, we automatically collect certain technical and usage information, including:

• Device Information: Device type (mobile, tablet, desktop), operating system (Android, iOS, Windows, macOS), browser type and version, screen resolution, device identifiers (IMEI, advertising ID)
• Connection Information: IP address, internet service provider (ISP), connection type (Wi-Fi, mobile data), network status
• Usage Data: Pages visited, time spent on pages, click-through rates, navigation paths, search queries on the Platform, referring and exit pages, date and time stamps of activity
• Transaction Data: Deposit amounts, deposit methods, withdrawal amounts, withdrawal methods, transaction dates and times, transaction IDs, payment processor information
• Gaming Activity: Bets placed (sport, market, odds, stake, outcome), games played (game type, provider, session duration), wins and losses, bonus claims and wagering progress, account balance changes
• Cookies and Tracking Technologies: Information collected via cookies, web beacons, pixel tags, and similar technologies (see Section 9 for detailed cookie information)

2.3 Information from Third Parties

tepe78 may receive information about you from third-party sources, including:

• Payment Providers: BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, cryptocurrency payment processors — providing transaction verification, fraud detection data, and payment status updates
• Identity Verification Services: Third-party KYC and anti-fraud services that verify your identity documents, check sanctions lists, and perform risk assessments
• Game Providers: Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, and other game suppliers — providing game session data, bet outcomes, and technical performance metrics
• Marketing Partners: Affiliate networks and marketing platforms that refer users to tepe78 — providing referral source, campaign identifiers, and conversion data
• Public Sources: Publicly available information from social media profiles (if you connect your account), government databases for identity verification, and online directories

3. How We Use Your Information

tepe78 uses the personal information we collect for the following purposes:

3.1 Service Provision and Account Management

• Creating, maintaining, and managing your tepe78 account
• Processing deposits, withdrawals, and other financial transactions
• Providing access to sports betting, live casino, slots, togel, and other gaming products
• Calculating and crediting winnings, bonuses, and loyalty rewards
• Verifying your identity, age (21+), and residency to comply with regulatory requirements
• Communicating with you about your account, transactions, and service updates

3.2 Security, Fraud Prevention, and Compliance

• Detecting, preventing, and investigating fraudulent activity, money laundering, bonus abuse, and other violations of our Terms & Conditions
• Conducting risk assessments and enhanced due diligence for high-value transactions
• Monitoring for duplicate accounts, collusion, arbitrage betting, and other prohibited activities
• Complying with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations
• Responding to legal requests, court orders, and regulatory inquiries from law enforcement and government authorities
• Enforcing our Terms & Conditions and protecting the rights, property, and safety of tepe78, our users, and the public

3.3 Platform Improvement and Personalization

• Analyzing usage patterns to improve Platform design, functionality, and user experience
• Personalizing content, game recommendations, and promotional offers based on your preferences and activity
• Conducting A/B testing and product development research
• Optimizing Platform performance, load times, and mobile responsiveness
• Troubleshooting technical issues and providing customer support

3.4 Marketing and Communications

• Sending promotional emails, SMS, and push notifications about bonuses, tournaments, new games, and special offers (only with your consent)
• Displaying targeted advertisements on the Platform based on your activity and preferences
• Conducting customer satisfaction surveys and requesting feedback on our Services
• Inviting you to participate in VIP programs, loyalty schemes, and exclusive events

3.5 Responsible Gaming

• Monitoring gaming behavior to identify potential problem gambling patterns
• Implementing deposit limits, loss limits, session time limits, and self-exclusion requests
• Providing access to responsible gaming tools and resources
• Contacting you with support offers if concerning activity is detected

4. Legal Basis for Processing (GDPR and Data Protection Principles)

Although tepe78 primarily serves Indonesian users, we adhere to international data protection best practices, including principles from the European Union's General Data Protection Regulation (GDPR). We process your personal information based on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our contract with you (providing betting and gaming services as outlined in our Terms & Conditions)
• Legal Obligation: Processing is required to comply with legal obligations, including KYC verification, AML/CTF regulations, age verification, and responding to legal requests
• Legitimate Interests: Processing is necessary for our legitimate business interests, including fraud prevention, security, platform improvement, and internal analytics, provided these interests do not override your privacy rights
• Consent: For marketing communications and non-essential cookies, we rely on your explicit consent, which you may withdraw at any time

5. How We Share Your Information

tepe78 does not sell your personal information to third parties for their own marketing purposes. However, we may share your information with the following categories of third parties as necessary to provide our Services:

5.1 Service Providers and Business Partners

• Payment Processors: Banks (BCA, BRI, BNI, Mandiri), e-wallet providers (OVO, DANA, GoPay), cryptocurrency payment gateways — to process deposits and withdrawals
• Game Providers: Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Ezugi, Spribe, and other game suppliers — to deliver gaming content and track play activity
• Identity Verification Services: Third-party KYC and fraud prevention providers — to verify your identity, check sanctions lists, and assess risk
• Cloud Storage and Hosting Providers: Secure servers and data centers that host the tepe78 Platform and store user data
• Customer Support Tools: Live chat software, email service providers, ticketing systems — to facilitate customer support communications
• Marketing and Analytics Providers: Email marketing platforms, analytics tools (Google Analytics, similar services), affiliate tracking systems — to measure marketing effectiveness and Platform performance

5.2 Legal and Regulatory Authorities

We may disclose your information to law enforcement, regulatory bodies, government agencies, courts, and other authorities when required by law, court order, subpoena, or regulatory investigation, or when we believe disclosure is necessary to protect our rights, comply with legal obligations, prevent fraud, or ensure public safety.

5.3 Corporate Transactions

In the event of a merger, acquisition, sale of assets, bankruptcy, or other corporate transaction involving tepe78, your personal information may be transferred to the acquiring or successor entity, subject to the same privacy protections outlined in this Privacy Policy.

5.4 Affiliate Partners and Marketing Networks

We may share limited information (such as referral source, conversion status, and aggregated statistics) with affiliate partners who referred you to tepe78, solely for the purpose of calculating referral commissions. We do not share your personally identifiable information with affiliates for their own marketing purposes.

Third-Party Category	Data Shared	Purpose
Payment Processors	Name, bank account details, transaction amounts	Process deposits and withdrawals
Game Providers	User ID, bets placed, game sessions	Deliver gaming content and track activity
KYC Services	Name, date of birth, identity documents	Verify identity and comply with regulations
Cloud Hosting	All account and activity data (encrypted)	Store and serve Platform infrastructure
Marketing Platforms	Email, anonymized usage data	Send promotional communications (with consent)

6. Data Security Measures

tepe78 employs comprehensive technical, administrative, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. Our security measures include:

6.1 Technical Security

• Encryption: SSL/TLS encryption (minimum 256-bit) for all data transmitted between your device and our servers; AES-256 encryption for data stored on our servers
• Secure Authentication: Password hashing using industry-standard algorithms; two-factor authentication (2FA) options for account access
• Firewall Protection: Network firewalls and intrusion detection/prevention systems (IDS/IPS) to block unauthorized access
• Vulnerability Management: Regular security audits, penetration testing, and vulnerability scanning conducted by independent third-party security firms
• DDoS Protection: Distributed Denial of Service (DDoS) mitigation to ensure Platform availability and resilience

6.2 Administrative Security

• Access Controls: Strict role-based access controls ensuring only authorized personnel can access personal data, on a need-to-know basis
• Employee Training: Mandatory data protection and security awareness training for all employees
• Background Checks: Thorough background checks for employees with access to sensitive data
• Data Minimization: Collection and retention of only the data necessary to provide Services
• Incident Response: Documented incident response plan for addressing data breaches and security incidents

6.3 Physical Security

• Secure Data Centers: Servers hosted in certified data centers with 24/7 physical security, biometric access controls, and environmental monitoring
• Backup Systems: Regular encrypted backups stored in geographically distributed locations for disaster recovery

7. Data Retention and Deletion

tepe78 retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Active Accounts: Personal data is retained for the duration of your account's active status
• Closed Accounts: After account closure, we retain core identity and transaction data for a minimum of 7 years to comply with financial record-keeping regulations, AML/CTF obligations, and potential legal claims
• Marketing Data: Marketing consent and communication preferences are retained until you withdraw consent or request deletion
• Usage Data: Anonymized usage and analytics data may be retained indefinitely for statistical and research purposes
• Legal Holds: Data subject to legal holds (due to investigations, litigation, or regulatory inquiries) is retained until the hold is lifted

Upon expiration of the retention period, personal data is securely deleted or anonymized such that it can no longer be attributed to you. You may request early deletion of your data by contacting [email protected], subject to our legal retention obligations.

8. Your Privacy Rights

Depending on your jurisdiction and applicable data protection laws, you may have the following rights regarding your personal information:

8.1 Right to Access

You have the right to request a copy of the personal information tepe78 holds about you. You can access most of your data directly through your account dashboard. For a comprehensive data export, contact [email protected].

8.2 Right to Rectification

You have the right to correct inaccurate or incomplete personal information. You can update your contact details, address, and payment methods directly in your account settings. For changes to identity information (name, date of birth), contact customer support with supporting documentation.

8.3 Right to Erasure ("Right to be Forgotten")

You have the right to request deletion of your personal data, subject to certain exceptions (e.g., legal retention requirements, fraud prevention, outstanding liabilities). To request deletion, contact [email protected]. Note that we may retain certain data for legal compliance purposes even after account closure.

8.4 Right to Restrict Processing

You have the right to request restriction of processing in certain circumstances, such as if you contest the accuracy of your data or object to processing. Contact [email protected] to exercise this right.

8.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format (e.g., CSV, JSON) and to transmit that data to another service provider. Contact [email protected] to request data export.

8.6 Right to Object

You have the right to object to processing of your personal data for direct marketing purposes. You can opt out of marketing communications by clicking the "unsubscribe" link in emails, adjusting preferences in your account settings, or contacting [email protected].

8.7 Right to Withdraw Consent

Where processing is based on consent (e.g., marketing communications, non-essential cookies), you have the right to withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

8.8 Right to Lodge a Complaint

If you believe tepe78 has violated your privacy rights or applicable data protection laws, you have the right to lodge a complaint with a supervisory authority in your jurisdiction.

To exercise any of these rights, contact our Data Protection Officer at [email protected] with your request and proof of identity. We will respond within 30 days.

9. Cookies and Tracking Technologies

tepe78 uses cookies, web beacons, pixel tags, and similar tracking technologies to enhance your experience, analyze Platform usage, and deliver targeted content. A cookie is a small text file stored on your device by your web browser. We use the following types of cookies:

• Strictly Necessary Cookies: Essential for Platform functionality, including login authentication, session management, and security. These cookies cannot be disabled.
• Performance Cookies: Collect anonymized data about how you use the Platform (pages visited, time spent, errors encountered) to improve performance and user experience.
• Functionality Cookies: Remember your preferences (language, currency, region) and provide personalized features.
• Marketing Cookies: Track your activity across websites to deliver targeted advertisements and measure campaign effectiveness. These cookies require your consent.

You can manage cookie preferences through your browser settings (most browsers allow you to block or delete cookies). Note that disabling cookies may impair Platform functionality and your user experience. For more information on managing cookies, visit your browser's help documentation.

10. International Data Transfers

tepe78 operates internationally and may transfer your personal information to servers and service providers located outside Indonesia, including in jurisdictions that may not offer the same level of data protection as Indonesia. When we transfer data internationally, we implement appropriate safeguards, including:

• Standard contractual clauses approved by data protection authorities
• Ensuring third-party service providers adhere to recognized data protection frameworks
• Encryption and security measures during transmission and storage

By using tepe78 Services, you consent to the international transfer of your personal data as described in this Privacy Policy.

11. Children's Privacy

tepe78 Services are strictly for individuals aged 21 years or older. We do not knowingly collect, use, or store personal information from individuals under 21. If we become aware that we have inadvertently collected data from a person under 21, we will delete that information immediately and close the account. Parents or guardians who believe their child has provided personal information to tepe78 should contact [email protected] immediately.

12. Changes to This Privacy Policy

tepe78 reserves the right to update, modify, or revise this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. Changes will be effective immediately upon posting on the Platform. We will notify you of material changes via email or prominent notice on the Platform. Your continued use of tepe78 Services after changes are posted constitutes acceptance of the updated Privacy Policy. We recommend reviewing this page periodically to stay informed of our privacy practices.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, your personal data, or our privacy practices, please contact our Data Protection Officer:

• Email: [email protected]
• Subject Line: Privacy Inquiry / Data Protection Request
• Live Chat: Available 24/7 on the tepe78 Platform

We aim to respond to all privacy inquiries within 30 days. For urgent matters (such as suspected unauthorized account access or data breaches), please contact us immediately via live chat or email with "URGENT" in the subject line.