Privacy Policy — a200m

1 Scope & Application

1.1 This Privacy Policy applies to all personal data collected and processed by a200m in connection with the operation of the online betting and casino platform accessible at https://a200m.pro (the "Platform"), including the sportsbook, live casino, slots, and togel online (Indonesia's traditional numbers lottery) sections.

1.2 This Policy applies to all current and former registered Members, as well as visitors who browse the Platform without registering an account. It governs data collected through the website, the mobile-optimized web application, customer support communications (email and live chat), and any other channel through which you interact with a200m.

1.3 This Privacy Policy should be read in conjunction with the a200m Terms & Conditions and Responsible Gaming Policy, which together form the complete framework governing your use of the Platform.

1.4 a200m operates primarily for users located in Indonesia. References to applicable law in this Policy encompass internationally recognized data protection principles as well as relevant Indonesian regulations governing the handling of personal data of Indonesian residents.

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2 Personal Data We Collect

2.1 a200m collects the minimum personal data necessary to provide a secure, compliant, and fully functional betting and gaming service. The categories of data we collect are set out in the table below:

Data Category	Specific Data Points
Identity Data	Full legal name, date of birth, Indonesian National Identity Card (KTP) number or passport number, nationality, gender.
Contact Data	Email address, Indonesian mobile phone number, residential address (including city — e.g., Jakarta, Surabaya, Bandung, Bali, Medan, Yogyakarta), postal code.
Account Data	Username, hashed password, account registration date, account status, self-exclusion status, responsible gaming limit settings.
Financial Data	Bank account details (bank name, account number, account holder name) for BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata, or Bank Danamon; e-wallet identifiers for OVO, DANA, GoPay, ShopeePay, and LinkAja; deposit and withdrawal transaction history denominated in IDR (Rp).
Transactional Data	Bet history, wagering records, game session data, bonus redemption history, win/loss records, togel draw participation records.
KYC Verification Data	Photographs of identity documents, proof-of-address documents, proof-of-payment-method documents submitted during the Know Your Customer (KYC) verification process.
Technical Data	IP address, device type and model, browser type and version, operating system, screen resolution, session timestamps, connection logs.
Usage Data	Pages visited, navigation paths, time spent on page, clicks, search queries within the Platform, game launch events.
Communications Data	Records of live chat conversations, email correspondence with our support team, and any feedback or complaints submitted.

2.2 a200m does not intentionally collect sensitive personal data categories such as racial or ethnic origin, political opinions, religious beliefs, health data (beyond what is relevant to responsible gaming interactions), or biometric data for identification purposes.

2.3 Where you provide us with data about third parties (for example, when nominating a bank account registered to a family member), you confirm that you have obtained the consent of that individual to share their data with a200m for the stated purpose.

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3 How We Collect Your Data

3.1 a200m collects personal data through the following channels:

• Direct submission: data you provide when registering an account, completing KYC verification, making deposits or withdrawal requests, contacting customer support, or participating in promotions;
• Automated collection: technical and usage data gathered automatically through cookies, web beacons, server logs, and similar tracking technologies when you visit or interact with the Platform (see Section 8 — Cookies & Tracking);
• Third-party payment processors: transaction confirmation data, fraud screening results, and payment method verification signals received from our banking and e-wallet partners;
• Identity verification providers: results and flags returned by third-party KYC and AML screening services used to verify the identity and eligibility of Members;
• Game studio partners: session and result data transmitted by our licensed game providers (including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft) in connection with your gameplay on the Platform.

3.2 You are not obligated to provide personal data to a200m; however, failure to provide data required for registration, KYC verification, or payment processing will prevent you from accessing the relevant features of the Platform.

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4 Purpose of Processing

4.1 a200m processes your personal data for the following purposes:

Purpose	Details
Account Management	Creating, maintaining, and securing your a200m account; authenticating your identity at login; communicating account-related notifications.
Service Delivery	Processing bets, settling wagers, crediting winnings, processing deposits and withdrawals in IDR, administering bonuses and promotions.
KYC & Compliance	Verifying your age (21+) and identity; conducting anti-money laundering (AML) screening; fulfilling obligations under our international gaming license.
Fraud Prevention & Security	Detecting and preventing fraudulent accounts, bonus abuse, multi-accounting, unauthorized access, and other prohibited conduct as defined in the Terms & Conditions.
Responsible Gaming	Monitoring betting patterns to identify at-risk behavior; administering deposit limits, loss limits, session reminders, and self-exclusion requests; complying with responsible gaming obligations.
Customer Support	Responding to queries, resolving disputes, processing complaints, and improving the quality of our 24/7 support service.
Platform Improvement	Analyzing usage patterns to improve navigation, game selection, performance, and overall user experience on the Platform.
Marketing Communications	Sending promotional offers, bonus notifications, and seasonal campaign updates (e.g., Ramadhan promotions, Idul Fitri bonuses, Indonesian Independence Day offers) — only where you have provided valid consent and not subsequently opted out.
Legal Obligations	Retaining records as required by applicable law; responding to lawful requests from regulatory or judicial authorities.

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5 Legal Basis for Processing

5.1 a200m processes your personal data on the following legal bases:

• Contractual necessity: the majority of processing activities — account creation, bet settlement, payment processing, KYC verification — are necessary for the performance of the contract between you and a200m (as set out in the Terms & Conditions);
• Legal obligation: certain data processing activities are required to comply with applicable AML regulations, gaming license conditions, and data retention mandates imposed by competent authorities;
• Legitimate interests: fraud prevention, platform security, internal analytics, and service improvement are carried out on the basis of a200m's legitimate business interests, which do not override your privacy rights;
• Consent: marketing communications and optional cookies are processed solely on the basis of your freely given, specific, informed consent, which you may withdraw at any time.

5.2 Where processing is based on consent, withdrawal of that consent does not affect the lawfulness of any processing carried out prior to the withdrawal.

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6 Data Sharing & Disclosure

6.1 a200m does not sell, rent, or trade your personal data to third-party advertisers or data brokers under any circumstances.

6.2 We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to contractual data protection obligations:

• Payment processors and banking partners (BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, LinkAja, and associated payment gateway providers) — to process deposits, withdrawals, and fraud screening;
• Identity and KYC verification providers — to authenticate your identity, age, and eligibility as required by our licensing obligations;
• Game studio partners (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, Pocket Games Soft, and others) — to deliver game sessions, settle outcomes, and maintain fair-play integrity;
• IT infrastructure and cloud service providers — to host the Platform and store data on secure, encrypted servers;
• Legal and regulatory authorities — when required by applicable law, court order, or the lawful request of a competent regulatory body;
• Professional advisers (lawyers, auditors, compliance consultants) — where necessary and subject to professional confidentiality obligations.

6.3 In the event of a business reorganization, merger, or acquisition, your personal data may be transferred to the acquiring entity, subject to that entity honoring the commitments in this Privacy Policy.

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7 Third-Party Services & Embedded Content

7.1 The a200m Platform integrates third-party services — including live casino studios, game aggregators, payment gateways, and fraud-detection tools — which may independently collect technical data such as your IP address, device fingerprint, and session metadata in order to deliver their services and maintain security.

7.2 Each third-party service provider operates under its own privacy policy and data processing agreements. a200m selects partners who demonstrate a commitment to data protection standards consistent with our own policies, and we enter into formal data processing agreements with all sub-processors.

7.3 a200m is not responsible for the independent data practices of third-party services accessed via external links. This Privacy Policy does not extend to any website, application, or service outside the a200m Platform.

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8 Cookies & Tracking Technologies

8.1 a200m uses cookies and similar tracking technologies (web beacons, pixel tags, local storage objects) to operate the Platform effectively, remember your preferences, and analyze usage patterns. The following categories of cookies are used:

Cookie Type	Purpose	Consent Required
Strictly Necessary	Essential for the Platform to function — session management, authentication tokens, security parameters, load balancing. Cannot be disabled.	No
Functional	Remembers your language preferences, game layout settings, and notification preferences to personalize your experience.	Yes
Analytical / Performance	Collects aggregated usage statistics (pages visited, session duration, error rates) used to improve Platform performance. Data is anonymized where possible.	Yes
Marketing / Targeting	Used to deliver relevant promotional content and track the effectiveness of marketing campaigns. a200m does not share this data with external ad networks.	Yes

8.2 You may manage your cookie preferences through your browser settings. Please note that disabling functional or analytical cookies may degrade certain features of the Platform.

8.3 Most cookies set by a200m expire at the end of your browsing session (session cookies). Persistent cookies — used to remember login status and preference settings — have a maximum lifespan of twelve (12) months, after which they are automatically deleted and re-issued upon your next login.

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9 Data Retention

9.1 a200m retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law and our gaming license conditions. The general retention schedule is as follows:

• Active account data: retained for the duration of your membership plus five (5) years following account closure, to satisfy AML record-keeping and licensing audit obligations;
• Financial transaction records: retained for a minimum of five (5) years from the date of each transaction in accordance with international AML standards;
• KYC documentation: retained for five (5) years after account closure or the completion of the KYC review, whichever is later;
• Customer support communications: retained for two (2) years from the date of the last interaction;
• Marketing consent records: retained for the duration of your membership and for two (2) years following withdrawal of consent, to demonstrate compliance;
• Technical / server log data: retained for a maximum of ninety (90) days in an identifiable form, after which it is anonymized or deleted.

9.2 Upon expiry of the applicable retention period, a200m will securely delete or anonymize your personal data in a manner that renders it irrecoverable and non-attributable to you.

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10 Security Measures

10.1 a200m implements a comprehensive, layered security framework to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. Our technical and organizational measures include:

• 256-bit TLS/SSL encryption for all data in transit between your device and our servers;
• AES-256 encryption for all sensitive data stored at rest, including KYC documents and financial records;
• Bcrypt password hashing — your a200m password is never stored in plain text; it is irreversibly hashed using a salted bcrypt algorithm;
• Two-factor authentication (2FA) available to all Members as an optional additional login security layer;
• Role-based access control (RBAC) — internal staff access to Member data is strictly limited to roles that require it, with full audit logging of all access events;
• Continuous intrusion detection and prevention systems monitoring all Platform traffic in real time;
• Regular third-party penetration testing and independent security audits conducted at least annually;
• Incident response procedures — in the event of a confirmed data breach affecting your personal data, a200m will notify affected Members within seventy-two (72) hours of becoming aware of the incident, consistent with responsible disclosure obligations.

10.2 While a200m takes all reasonable precautions, no internet-based system can guarantee absolute security. Members are responsible for maintaining the confidentiality of their own login credentials and for ensuring their devices are protected by up-to-date antivirus and firewall software.

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11 Your Data Protection Rights

11.1 As a registered Member of a200m, you have the following rights with respect to your personal data. These rights may be exercised by contacting our privacy team at [email protected]:

11.2 To exercise any of the above rights, please submit a written request to [email protected] with the subject line "Data Rights Request — [Your Username]". a200m will acknowledge your request within five (5) business days and provide a substantive response within thirty (30) calendar days. In complex cases, this period may be extended by a further thirty (30) days with prior notification.

11.3 We may need to verify your identity before processing a data rights request to prevent unauthorized access to another Member's data. Identity verification for data rights requests is conducted separately from account KYC and does not affect your account status.

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12 Minors & Age Restriction

12.1 The a200m Platform is strictly for adults aged 21 years and older. We do not knowingly collect personal data from any individual under the age of 21.

12.2 If a200m discovers or is notified that personal data has been collected from a person under 21, we will immediately close the associated account, void all balances and wagering activity, and securely delete the personal data collected, consistent with our legal obligations.

12.3 If you are a parent or guardian and believe that a minor has registered an account on a200m using false age information, please contact us immediately at [email protected] with the subject line "Underage Account Report".

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13 International Data Transfers

13.1 a200m operates internationally, and your personal data may be transferred to and processed in countries outside Indonesia, including the jurisdictions where our servers, cloud infrastructure, and licensed game studio partners are located.

13.2 Where personal data is transferred outside Indonesia to countries that do not offer an equivalent level of data protection, a200m implements appropriate safeguards including:

• Standard contractual clauses incorporating data protection obligations that are consistent with international best practices;
• Binding corporate rules or equivalent frameworks applicable to intra-group data transfers;
• Transfer impact assessments for high-risk transfer scenarios to confirm that the rights of Indonesian Members are not undermined by the transfer.

13.3 All sub-processors and third-party partners receiving data transfers from a200m are contractually obligated to apply data protection standards consistent with this Privacy Policy.

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14 Changes to This Privacy Policy

14.1 a200m reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. The most current version will always be published at https://a200m.pro/privacy-policy, with the "Last Updated" date revised accordingly.

14.2 Where a proposed change materially affects how we process your personal data, a200m will notify registered Members by email to the address on file at least fourteen (14) days before the revised policy takes effect.

14.3 Your continued use of the Platform after the effective date of any change constitutes acceptance of the revised Privacy Policy. If you object to any change, you may request account closure by contacting [email protected] before the effective date.

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15 Contact Our Privacy Team

15.1 For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact the a200m privacy team using the details below:

• Email: [email protected] — subject line: "Privacy Inquiry" or "Data Rights Request — [Your Username]"
• Live Chat: Available 24 hours a day, 7 days a week via the chat widget on the Platform; request to speak with a Privacy or Compliance team member
• Response Commitment: All privacy-related emails are acknowledged within five (5) business days (WIB) and substantively resolved within thirty (30) calendar days

15.2 For responsible gaming concerns — including self-exclusion requests, deposit limit changes, or session reminders — please visit our dedicated Responsible Gaming page or contact support directly using the same email address above.