Privacy Policy — ug181

Throughout this Privacy Policy, the following terms carry the meanings defined below. Singular forms include the plural and vice versa where context requires.

ug181 collects only the Personal Data that is necessary to provide a safe, compliant, and high-quality gaming service to Members in Indonesia. The categories of data we collect are as follows:

We do not collect sensitive Personal Data such as racial or ethnic origin, political opinions, religious beliefs, or biometric data beyond what is strictly required for identity document verification during KYC.

ug181 collects Personal Data through the following channels:

• Direct submission: Information you provide when registering an account, completing KYC verification, submitting a deposit or withdrawal request, contacting live chat or email support, or participating in a promotion.
• Automated technical collection: Data gathered automatically when you access the Platform, including IP addresses, cookies, browser fingerprints, session data, and device identifiers. This collection occurs through standard web server logs and first-party analytics tools.
• Transaction systems: Financial data transmitted by your bank or e-wallet provider (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, LinkAja, and others) in connection with deposits and withdrawals.
• Third-party verification services: In limited circumstances, the Company may use third-party identity verification services to cross-reference KYC documents against public records for fraud prevention purposes.
• Responsible gaming tools: Where a Member activates deposit limits, session reminders, or self-exclusion, the resulting data is logged to enforce those restrictions and protect the Member's account.

ug181 uses the Personal Data it holds for the following purposes:

1. Account administration: Creating, maintaining, and securing your ug181 Account, including verifying your identity at registration and at the time of any withdrawal request.
2. Service delivery: Enabling you to place wagers on sports events, play casino games, participate in *togel* (Indonesia's traditional numbers lottery) draws, and access all other Platform features.
3. Financial processing: Executing and recording your IDR deposits and withdrawals via your nominated Indonesian bank account or e-wallet.
4. Fraud prevention and security: Detecting and investigating suspicious account activity, collusion, multi-accounting, and money laundering attempts. IP analysis and device fingerprinting are core tools in this effort.
5. Regulatory compliance: Meeting the Company's obligations under applicable anti-money laundering (AML) and counter-terrorism financing (CTF) frameworks, including the retention of transaction records for the periods required by applicable law.
6. Responsible gaming: Monitoring transaction patterns and gameplay data to identify signs of problem gambling and to enforce any self-exclusion, deposit limit, or account restriction a Member has activated.
7. Customer support: Responding to inquiries, resolving disputes, and maintaining records of communications for quality assurance and evidence purposes.
8. Marketing communications: Sending promotional offers, bonus notifications, and seasonal promotions (relating to events such as Idul Fitri, Ramadhan, and Indonesian Independence Day) — only where you have given express opt-in consent. You may withdraw consent at any time via your account settings or by contacting live chat.
9. Platform improvement: Analyzing aggregated, anonymized usage data to identify performance issues, improve product features, and optimize the user experience for Indonesian Members.

The Company processes Personal Data on the following legal grounds:

• Contractual necessity: Processing required to perform the contract between the Company and the Member — including account creation, game access, and payment processing.
• Legal obligation: Processing required to comply with applicable AML, CTF, and data retention laws.
• Legitimate interests: Processing conducted for fraud prevention, Platform security, and service improvement — where those interests are not overridden by your individual privacy rights.
• Consent: Processing for direct marketing communications, where you have explicitly opted in. This consent may be withdrawn at any time without affecting the lawfulness of prior processing.

ug181 does not sell, rent, or trade your Personal Data to third parties for their own commercial purposes. We share Personal Data only in the limited circumstances described below, and only to the extent strictly necessary for the stated purpose:

All Third-Party Processors engaged by ug181 are bound by contractual data-processing agreements that prohibit them from using your Personal Data for any purpose other than the one for which it was shared, and that require them to maintain security standards equivalent to those applied by the Company.

ug181 retains Personal Data only for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable legal and regulatory obligations. The following retention periods apply:

Once the applicable retention period expires, Personal Data is securely deleted or irreversibly anonymized so that it can no longer be linked to any individual. Anonymized, aggregated data may be retained indefinitely for statistical and product development purposes.

The Company applies industry-standard technical and organizational security measures to protect your Personal Data against unauthorized access, accidental loss, disclosure, alteration, or destruction. Key measures in place include:

• 256-bit SSL/TLS encryption applied to all data in transit between your browser and the ug181 Platform.
• Encryption at rest for all stored Personal Data and KYC documents using AES-256 encryption.
• Access controls: Strict role-based access controls ensure that only authorized Company personnel with a legitimate operational need can access Personal Data. All access is logged and audited.
• Two-factor authentication (2FA) available to all Members for additional account security and enforced for all Company staff accessing internal systems.
• Automated fraud monitoring: Real-time systems analyze transaction and login patterns to detect and flag anomalous activity for investigation.
• Regular security audits: The Platform undergoes periodic third-party penetration testing and vulnerability assessments to identify and remediate security risks proactively.
• Data breach response: In the event of a confirmed data breach that poses a risk to your rights, the Company will notify affected Members and relevant authorities within the timeframe required by applicable law.

ug181 uses cookies and similar tracking technologies to operate the Platform effectively and to improve your experience as an Indonesian Member. Cookies are small text files placed on your device when you visit the Platform.

The following categories of cookies are used:

You may manage or delete cookies through your browser settings at any time. Please note that disabling strictly necessary cookies will impair your ability to use the Platform, including logging in and processing transactions. Disabling functional or analytics cookies will not affect your ability to place wagers or access games.

As a Member of ug181, you hold the following rights in relation to your Personal Data. To exercise any of these rights, please contact our support team via live chat or at [email protected]. We will respond to verified requests within 30 calendar days.

1. Right of access: You may request a copy of the Personal Data that ug181 holds about you, along with information about how it is being used.
2. Right to rectification: If any Personal Data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it. You may update basic account details directly from your account settings page.
3. Right to erasure: You may request that we delete your Personal Data where it is no longer necessary for the purposes for which it was collected. Please note that this right is subject to legal retention obligations — we cannot delete transaction records that we are legally required to retain for AML/CTF compliance purposes.
4. Right to restrict processing: You may request that we temporarily suspend our use of your Personal Data while an accuracy dispute is being resolved, or pending a legitimate interests assessment.
5. Right to data portability: Where processing is based on your consent or contractual necessity, and is carried out by automated means, you may request that we provide your Personal Data in a structured, machine-readable format.
6. Right to object: You may object to processing carried out on the basis of legitimate interests at any time. You may also withdraw consent to marketing communications at any time without affecting your account status.
7. Right not to be subject to solely automated decisions: Where any significant decision about your account is made by automated systems alone (for example, a fraud flag resulting in account suspension), you have the right to request human review of that decision.

The ug181 Platform does not contain links to third-party websites for general browsing purposes. However, payment processing flows may redirect you temporarily to your bank's or e-wallet provider's interface (for example, BCA's internet banking portal or OVO's app) to authorize a transaction. These third-party interfaces are governed by their own privacy policies, over which ug181 has no control.

The Company recommends that you review the privacy policies of BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata, OVO, DANA, GoPay, ShopeePay, and LinkAja independently to understand how those institutions handle your financial data during payment authorization.

The ug181 Platform is strictly restricted to individuals aged 21 years or older. The Company does not knowingly collect Personal Data from persons under the age of 21. Age verification is a mandatory step in the account registration and KYC processes.

If the Company becomes aware — through KYC review, third-party report, or any other means — that Personal Data belonging to a person under 21 has been collected, it will immediately close the associated account, return any real-money balance to the verified payment source, and permanently delete all Personal Data associated with that account.

If you believe that a person under 21 has registered an account on the Platform, please contact our support team immediately at [email protected]. We take underage access reports with the utmost seriousness and will act on them without delay. For further guidance on protecting minors from online gambling harm, please visit our Responsible Gaming page.

The Company reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, our data practices, or the services we offer. When material changes are made, we will:

• Update the "Last Updated" date displayed in the page header above.
• Publish the revised Policy on this page at https://ug181.pro/privacy-policy.
• Notify registered Members of significant changes via the email address on file or via an in-platform notification prior to the effective date of the change.

Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acknowledgment of and agreement to the revised terms. If you do not agree with any material changes to this Policy, you must cease using the Platform and may request account closure in accordance with Clause 8 of our Terms & Conditions. We encourage you to review this page periodically to remain informed of how ug181 handles your Personal Data.

If you have any questions about this Privacy Policy, wish to exercise any of your privacy rights, or want to raise a data-related concern, please reach out to the Company through the channels below:

• Live Chat: Available 24 hours a day, 365 days a year, directly through the Platform. Our Indonesian-speaking support team has an average first-response time of under 90 seconds and can handle privacy rights requests, data queries, and urgent security concerns in real time.
• Email: [email protected] — written requests are acknowledged within 24 hours and fully resolved within 30 calendar days.

When submitting a privacy rights request, please provide your full registered name, the email address associated with your ug181 Account, and a clear description of your request. We may need to verify your identity before processing your request to protect against unauthorized data access.

If you are dissatisfied with our response to any privacy concern, you have the right to escalate the matter to the relevant data protection authority in the jurisdiction in which the Company holds its operating license. The Company will cooperate fully with any such regulatory inquiry.