batak5 Privacy Policy

1.1 This Privacy Policy describes how batak5 ("we", "us", "our"), the operator of the online betting platform at https://batak5.cam, collects, uses, discloses, retains, and protects personal data relating to individuals who visit, register with, or otherwise interact with the Platform.

1.2 batak5 is primarily designed for English-preference users in Indonesia and serves a broad international audience. We recognise the importance of personal data privacy across all the markets in which we operate, and we commit to handling your data responsibly, transparently, and in accordance with internationally recognised data protection principles.

1.3 By registering a batak5 Account or continuing to use the Platform after this Policy has been published or updated, you acknowledge that you have read and understood its contents. If you do not agree with any part of this Policy, you should discontinue use of the Platform and close your Account.

1.4 This Privacy Policy should be read together with our Terms & Conditions and our Responsible Gaming policy, all of which form part of the contractual relationship between you and batak5.

Throughout this Privacy Policy, the following terms have the meanings given below:

• "Personal Data" — any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, ID number, location data, or online identifier.
• "Processing" — any operation performed on Personal Data, including collection, recording, organisation, structuring, storage, adaptation, retrieval, consultation, use, disclosure, erasure, or destruction.
• "Controller" — batak5, which determines the purposes and means of processing Personal Data.
• "Processor" — a third-party service provider that processes Personal Data on behalf of and under instruction from batak5.
• "Member" — any individual who has completed Account registration on the Platform.
• "Visitor" — any individual who browses the Platform without registering or logging in.
• "KYC" — Know Your Customer; the identity, age, and address verification process required of all Members before withdrawal processing.
• "Sensitive Data" — a subset of Personal Data warranting heightened protection: government-issued ID numbers, financial account details, and any data that could reveal health status or, in certain jurisdictions, religious affiliation.

3.1 batak5 collects Personal Data across three broad categories: data you provide directly, data generated automatically by your use of the Platform, and data obtained from authorised third parties.

3.2 Data You Provide Directly:

3.3 Data Generated Automatically:

• IP address and geolocation data (city/region level — not precise GPS coordinates).
• Device identifiers, browser type, operating system version, and screen resolution.
• Session timestamps, pages visited, features used, and session duration.
• Betting and gaming activity logs: markets selected, wager amounts, game titles played, and outcomes.
• Cookie and similar tracking technology data (see Section 10 for full details).

3.4 Data from Third Parties:

• Identity verification results from regulated KYC service providers.
• Transaction confirmation data from payment processors and Indo nesian banking partners.
• Fraud-risk scores and sanctions screening results from compliance data providers.
• Affiliate tracking data where a Member registers via a batak5 affiliate partner link.

4.1 Personal Data is collected through the following channels and mechanisms:

• Account Registration Form: When you create a batak5 account, you supply registration data directly through our online form.
• KYC Document Upload: When you submit identity documents through the secure document upload portal in your Account dashboard.
• Deposit and Withdrawal Requests: When you initiate a financial transaction, payment details are captured through our cashier interface and transmitted securely to our payment processing partners.
• Customer Support Channels: When you contact batak5 via live chat or email, conversation data is recorded for quality assurance, training, and dispute resolution purposes.
• Platform Usage: Automatically, through server logs, cookies, and similar technologies, as you browse and interact with the Platform.
• Promotional Participation: When you opt into a promotion, bonus offer, or tournament, relevant participation data is recorded against your Account.

4.2 batak5 does not collect Personal Data through covert means. All data collection is disclosed in this Policy or, where required, through a specific notice presented at the point of collection.

5.1 batak5 processes your Personal Data for the following specific, documented purposes:

1. Account Management: To create, maintain, and administer your batak5 Account, including verifying your identity and age at registration and at any subsequent point we are required to do so.
2. Transaction Processing: To process deposits and withdrawals via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, LinkAja, and other supported payment channels, and to maintain accurate financial records.
3. KYC and Regulatory Compliance: To meet our obligations under international anti-money laundering (AML) and counter-terrorism financing (CTF) frameworks, including verifying the source of funds where required.
4. Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, account compromise, bonus abuse, and any other conduct that threatens the integrity of the Platform or the interests of other Members.
5. Service Personalisation: To tailor the Platform experience to your preferences — such as surfacing relevant sports markets, recommending game categories aligned with your history, and presenting personalised promotional offers where you have consented to marketing.
6. Customer Support: To respond to your enquiries, resolve disputes, and maintain records of interactions for quality assurance and training purposes.
7. Responsible Gaming: To monitor account activity for indicators of problem gambling and to administer self-exclusion, deposit limit, and cooling-off tools requested by Members.
8. Legal Obligations: To comply with applicable laws, regulatory requirements, court orders, and lawful requests from competent authorities.
9. Platform Improvement: To analyse aggregated and anonymised usage data in order to improve Platform performance, identify technical issues, and develop new features.
10. Marketing Communications: To send promotional offers, bonus notifications, and product updates to Members who have opted in. This is always conditional on explicit consent and you may withdraw consent at any time.

5.2 batak5 does not use Personal Data for purposes incompatible with those listed above. If a new processing purpose arises that is materially different from those described here, we will notify affected Members and, where required, seek fresh consent before proceeding.

6.1 batak5 relies on one or more of the following lawful bases when processing your Personal Data:

• Contractual Necessity: Processing that is necessary to perform our contract with you — including operating your Account, processing transactions, and delivering the Services you have requested.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including AML/CTF obligations, KYC requirements imposed by our gaming licence, and data retention mandates.
• Legitimate Interests: Processing necessary for our legitimate business interests — such as fraud prevention, platform security, and service improvement — where those interests are not overridden by your rights and interests.
• Consent: Processing that you have explicitly agreed to, most notably the sending of marketing communications. Where consent is the basis, you have the right to withdraw it at any time without affecting the lawfulness of prior processing.

7.1 batak5 does not sell, rent, or trade your Personal Data. We may share your data with third parties only in the limited circumstances described below, and only to the minimum extent necessary for the stated purpose.

7.2 Service Providers (Processors): We engage regulated third-party processors to assist in delivering our services. These include:

• KYC and Identity Verification Providers: To verify your identity documents and screen against sanctions and politically exposed person (PEP) databases.
• Payment Processors and Banking Partners: Indonesian banking institutions and e-wallet operators (including BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja) and their technical service providers, to facilitate deposits and withdrawals.
• Cloud Infrastructure Providers: To host Platform data securely on enterprise-grade, encrypted cloud infrastructure.
• Fraud Detection and Cybersecurity Providers: To monitor for suspicious activity and protect the Platform against threats.
• Customer Support Platform Providers: To operate and store live chat and email support interactions.

All processors operate under binding data processing agreements that prohibit them from using your data for any purpose beyond their specific contracted role.

7.3 Regulatory and Legal Disclosures: batak5 may disclose Personal Data to regulatory authorities, law enforcement agencies, or courts when required to do so by applicable law, a valid court order, or our gaming licence conditions. We will, where legally permissible, notify affected Members of such disclosures.

7.4 Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of batak5's assets, Personal Data held by batak5 may be transferred to the acquiring entity as part of that transaction. Affected Members will be notified in advance, and the acquiring entity will be required to honour the commitments made in this Privacy Policy.

7.5 Affiliate Partners: If you registered via an affiliate partner link, we may share limited, aggregated account status data (e.g., whether an Account was verified and made a qualifying deposit) with that affiliate for commission-tracking purposes. No detailed financial or identity data is shared with affiliates.

8.1 batak5 retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations.

8.2 Retention Periods:

8.3 Where Personal Data is no longer required, batak5 will securely delete or anonymise it in a manner that prevents recovery or re-identification. Anonymised, aggregated data may be retained indefinitely for statistical and analytical purposes.

9.1 batak5 implements a multi-layered security architecture designed to protect Personal Data against unauthorised access, disclosure, alteration, and destruction. Our security programme includes:

• Transport Security: All data in transit is encrypted using TLS 1.3. Older, insecure protocol versions (SSL, TLS 1.0, TLS 1.1) are disabled.
• Data at Rest Encryption: Sensitive data stored on our servers is encrypted using AES-256. Encryption keys are managed through a dedicated, access-controlled key management system.
• Access Controls: Access to Personal Data within batak5's systems is restricted on a strict need-to-know basis. Employees undergo background screening and receive regular data protection training.
• Multi-Factor Authentication: Administrative access to systems containing Personal Data requires multi-factor authentication. Members are encouraged to enable available two-step verification features on their own Accounts.
• Penetration Testing: batak5 engages independent cybersecurity firms to conduct regular penetration tests and vulnerability assessments of the Platform infrastructure.
• Incident Response: A documented data breach response plan is maintained and tested regularly. In the event of a breach affecting your Personal Data, batak5 will notify you and relevant authorities within the timeframes required by applicable law.

9.2 While batak5 takes every reasonable precaution, no online system can be guaranteed to be completely secure. You are responsible for maintaining the security of your own Account credentials. If you suspect your Account has been compromised, contact us immediately at [email protected].

10.1 batak5 uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device by the Platform when you visit. Cookies do not contain your full Personal Data and cannot run programmes or deliver viruses.

10.2 Types of Cookies We Use:

10.3 You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair core Platform functionality, including login persistence. Disabling analytics or marketing cookies will not affect your ability to use the Platform.

10.4 In addition to cookies, batak5 may use web beacons (transparent pixel images embedded in emails) to confirm that marketing emails have been opened. These beacons record only the fact of email opening and do not collect any additional Personal Data from your device.

11.1 batak5 recognises and upholds the following rights in relation to your Personal Data. To exercise any of these rights, please contact our Data Protection team at [email protected] with the subject line "Data Rights Request".

• Right of Access: You may request a copy of the Personal Data batak5 holds about you, along with information about how it is used and with whom it has been shared. We will respond within 30 days of receiving a verified request.
• Right to Rectification: If any Personal Data we hold about you is inaccurate or incomplete, you have the right to have it corrected. Minor corrections (e.g., email address or phone number) may be made directly through your Account settings.
• Right to Erasure: 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, or where processing is unlawful. This right is subject to overriding legal retention obligations — for example, we cannot delete transaction records that we are required by law to retain for a minimum period.
• Right to Restriction: You may request that batak5 restrict processing of your Personal Data in certain circumstances — for example, while a dispute regarding accuracy is being resolved.
• Right to Data Portability: Where processing is based on your consent or on a contract, and is carried out by automated means, you may request that we provide your Personal Data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests, including profiling for direct marketing. Where you object to marketing, we will cease that processing immediately.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

12.1 The batak5 Platform is strictly for adults aged 21 years and older. We do not knowingly collect, process, or store Personal Data relating to any individual under the age of 21.

12.2 If batak5 becomes aware that Personal Data has been collected from an individual under 21, we will immediately close the associated Account, void any wagers, and permanently delete all data relating to that individual from our systems, subject only to any overriding legal obligation to retain evidence of the underage registration.

12.3 If you believe that a minor has registered a batak5 Account, please notify us immediately at [email protected] so that we can investigate and take appropriate action promptly.

13.1 batak5 operates globally, and some of the third-party service providers we work with — including cloud infrastructure, KYC verification, and fraud prevention partners — may process your Personal Data in countries outside Indonesia.

13.2 Where Personal Data is transferred to a country that does not provide a level of data protection equivalent to internationally recognised standards, batak5 will implement appropriate safeguards, which may include:

• Standard contractual clauses approved by competent data protection authorities.
• Binding corporate rules where transfers occur within a corporate group.
• Transfer impact assessments to evaluate whether the destination jurisdiction's laws undermine the protections afforded by the contractual safeguards.

13.3 By using the batak5 Platform, you acknowledge that your Personal Data may be transferred and processed in jurisdictions outside Indonesia. We take every reasonable measure to ensure that such transfers are lawful and that your data receives an equivalent standard of protection wherever it is processed.

14.1 batak5 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or our business operations. The "Last Updated" date displayed at the top of this page indicates when the most recent revision was made.

14.2 Where a change is material — meaning it significantly alters how your Personal Data is processed, reduces your rights, or introduces a new category of data sharing — we will notify you by email to your registered address at least 14 days before the change takes effect. For non-material clarifications or editorial corrections, the updated Policy will take effect immediately upon publication.

14.3 Continued use of the Platform after a revised Policy takes effect constitutes your acceptance of the updated terms. If you do not accept a material change, you should close your Account before the effective date of the revision and withdraw any available balance.

15.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the way batak5 processes your Personal Data, please contact our Data Protection team using the details below:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line for Data Requests: "Data Rights Request" or "Privacy Enquiry"
• Response Time: Within 2 business days for general enquiries; within 30 days for formal data rights requests
• Support Hours: 24 hours a day, 7 days a week, in English and Indonesian

15.2 If you are not satisfied with batak5's response to a data protection concern, you have the right to escalate your complaint to the competent data protection authority in your jurisdiction of residence. batak5 will cooperate fully with any such authority in the resolution of complaints.