Privacy Policy

1 Scope & Application

This Privacy Policy governs the collection, use, storage, disclosure, and protection of personal data by 1121ot ("the Company", "we", "us", "our") in connection with the operation of the 1121ot online gaming Platform. It applies to all registered Players and all visitors who access the Platform, regardless of device type or access method.

This Policy should be read in conjunction with our Terms & Conditions and our Responsible Gaming policy, both of which form part of the overall contractual and compliance framework governing your relationship with 1121ot.

2 Definitions

• "Personal Data" means any information that identifies or could reasonably be used to identify a natural person, directly or in combination with other data held by 1121ot.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, consultation, use, disclosure, erasure, or destruction.
• "Data Controller" means 1121ot, the entity that determines the purposes and means of processing Personal Data relating to its Players.
• "Data Processor" means a third party that processes Personal Data on behalf of 1121ot under a contractual arrangement and in accordance with our instructions.
• "Player" / "You" means any natural person who has registered an Account on the 1121ot Platform or who accesses the Platform without completing registration.
• "KYC" means Know Your Customer — the identity verification process 1121ot conducts to confirm a Player's identity, age, and ownership of payment methods prior to processing withdrawals.
• "Cookies" means small text files stored on your device by a web browser at the instruction of the 1121ot Platform, used to remember session information, preferences, and behavioral data.
• "Sensitive Data" means a subset of Personal Data that warrants heightened protection, including copies of government-issued identity documents, financial account details, and any health-related information provided in connection with responsible gaming tools.

3 Data We Collect

3.1 Registration Data

When you create an Account on 1121ot, we collect the following information:

• Full legal name (as it appears on your government-issued identification document)
• Date of birth (to verify you meet the 21+ age requirement)
• Email address
• Indonesian mobile phone number
• Preferred username and encrypted password
• Preferred bank account details: bank name (e.g., BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata), account number, and account holder name
• Preferred e-wallet details where applicable (OVO, DANA, GoPay, ShopeePay, or LinkAja)

3.2 KYC Verification Data

Prior to processing your first withdrawal, or at any point where our compliance team deems verification necessary, we may collect:

• A scanned copy or photograph of your national identity card (KTP), passport, or driving license
• Proof of address documentation (utility bill, bank statement, or official correspondence issued within the last 90 days)
• Selfie photograph for facial liveness verification
• Bank statement or e-wallet screenshot confirming ownership of the payment method linked to your Account

3.3 Transactional Data

For every deposit, withdrawal, and wagering activity conducted on the Platform, we record:

• Transaction amounts in Indonesian Rupiah (IDR) and timestamps
• Payment method used and partially masked account identifiers
• Game type, bet amount, outcome, and session duration for all wagers placed
• Bonus credits claimed and wagering requirement progress

3.4 Technical & Device Data

Automatically collected when you access the Platform:

• IP address and approximate geolocation (country and city level)
• Device type, operating system, and browser version
• Session timestamps, pages visited, and navigation patterns
• Referral URL (the page from which you arrived at 1121ot)

3.5 Communications Data

When you contact our customer support team, we retain records of the communication, including the content of live chat transcripts, email correspondence sent to or from [email protected], and any attachments or documents you share with our team in the course of resolving a query.

4 How We Collect Data

1121ot collects Personal Data through the following channels:

• Directly from you — through Account registration forms, KYC submission, payment processing inputs, responsible gaming tool configurations, and all interactions with our customer support team.
• Automatically — through cookies, web beacons, server logs, and similar tracking technologies embedded in the Platform that record technical and behavioral data each time you visit or interact with the site.
• From third-party service providers — including our payment processing partners (banks and e-wallet operators), identity verification service providers, and fraud detection systems, which may supply additional data points to supplement what you have provided directly.
• From publicly available sources — in limited circumstances relating to fraud prevention and AML compliance, we may cross-reference publicly available databases to verify the accuracy of information you have provided.

5 How We Use Your Data

1121ot uses your Personal Data exclusively for the following documented purposes:

Purpose	Data Categories Used
Account creation and authentication	Registration data, device data
Identity and age verification (KYC)	KYC documents, registration data
Processing deposits and withdrawals in IDR	Transactional data, registration data
Fraud prevention and AML compliance	All categories, as necessary
Delivering and personalizing gaming services	Transactional data, technical data
Responsible gaming monitoring and intervention	Transactional data, communications data
Customer support and dispute resolution	Communications data, transactional data
Marketing communications (opt-in only)	Registration data, transactional data
Platform security and technical improvements	Technical and device data
Legal and regulatory compliance	All categories, as required by law

6 Legal Basis for Processing

1121ot processes your Personal Data on one or more of the following legal bases, depending on the specific purpose of processing:

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions you accepted at registration — such as Account management, payment processing, and game delivery.
• Legitimate interests: Processing necessary for 1121ot's legitimate business interests, including fraud prevention, platform security, and service improvement, provided those interests are not overridden by your fundamental rights.
• Legal obligation: Processing required to comply with applicable anti-money-laundering (AML) obligations, age verification requirements, and any lawful request from a competent authority.
• Consent: Where we rely on your consent — particularly for marketing communications — you may withdraw that consent at any time by updating your notification preferences in Account settings or by emailing [email protected].

7 Data Sharing & Disclosure

1121ot does not sell your Personal Data to any third party. We may share your 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, Bank Permata, OVO, DANA, GoPay, ShopeePay, and LinkAja receive only the minimum data required to execute and confirm your financial transactions.
• Identity verification providers — Third-party KYC service providers receive your identity documents and biometric data exclusively for the purpose of confirming your identity and age. These providers are contractually prohibited from using your data for any other purpose.
• Game content providers — Providers such as Evolution Gaming, Pragmatic Play, Microgaming, NetEnt, Pocket Games Soft, and Spribe may receive anonymized session data to enable the delivery of their game content within the 1121ot Platform.
• Fraud and AML screening services — We work with specialist compliance technology providers to screen transactions and player profiles against risk indicators. These providers process data under strict confidentiality agreements.
• Legal and regulatory authorities — In response to a lawful order, subpoena, or formal regulatory request, 1121ot may be required to disclose specific player data to a competent authority. We will notify you of any such disclosure to the extent permitted by law.

8 Cookies & Tracking Technologies

8.1 Types of Cookies Used

The 1121ot Platform uses the following categories of cookies:

• Essential cookies: Required for the Platform to function correctly. These cookies manage your login session, maintain your Account state across pages, and ensure security features operate properly. They cannot be disabled without impairing your ability to use the Platform.
• Functional cookies: Used to remember your preferences, such as your preferred language, display settings, and previously used payment methods, so you do not need to re-enter them on each visit.
• Analytical cookies: Used to collect aggregated, anonymized data about how Players navigate the Platform. This data helps us identify pages with performance issues, optimize the user experience, and prioritize feature development.
• Marketing cookies (opt-in): With your consent, we may use cookies to deliver promotional content relevant to your gaming activity and preferences on the 1121ot Platform only. We do not use cross-site tracking cookies to follow your activity on other websites.

8.2 Managing Cookies

You can manage or disable non-essential cookies at any time through your browser settings. Please note that disabling functional or analytical cookies may affect certain aspects of your experience on the Platform. Essential cookies cannot be disabled as they are strictly necessary for the Platform's core operation.

9 Data Retention

1121ot retains Personal Data only for as long as is necessary to fulfill the purpose for which it was collected, subject to the following minimum retention periods:

• Account and registration data: Retained for the duration of the Account's active status plus a minimum of five (5) years following Account closure, in compliance with AML record-keeping requirements.
• KYC documents: Retained for a minimum of five (5) years from the date of verification or the date of Account closure, whichever is later.
• Transactional records: Retained for a minimum of five (5) years to support financial auditing, dispute resolution, and regulatory compliance obligations.
• Customer support communications: Retained for three (3) years following the resolution of the relevant inquiry or complaint.
• Marketing consent records: Retained for the period during which consent is active plus two (2) years thereafter as evidence of the consent obtained.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymized in accordance with our internal data destruction procedures.

10 Security Measures

1121ot implements a multi-layered security framework to protect your Personal Data against unauthorized access, accidental loss, destruction, or disclosure. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers
• Encrypted storage of all Sensitive Data at rest using industry-standard encryption protocols
• Role-based access controls ensuring that only authorized personnel with a documented operational need can access player data
• Multi-factor authentication (MFA) required for all internal staff accessing player records
• Regular independent security audits and penetration testing of the Platform and underlying infrastructure
• Automated intrusion detection and real-time threat monitoring systems operating around the clock across WIB, WITA, and WIT time zones

11 Your Rights

As a Player of 1121ot, you hold the following rights with respect to your Personal Data. To exercise any of these rights, submit a written request to [email protected] with the subject line "Data Rights Request". We will respond within 30 days of receipt.

12 Minors

The 1121ot Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect Personal Data from individuals under the age of 21. If we become aware that a person under 21 has provided us with Personal Data or has registered an Account, we will immediately close the Account, delete all associated Personal Data, and void any transactions or balances linked to that Account. Adults only — 21+ only.

If you are a parent or guardian and believe that a minor in your care has accessed the 1121ot Platform, please contact us immediately at [email protected] so that we can take prompt action.

13 International Data Transfers

As an internationally operated gaming platform serving Indonesian players, 1121ot may transfer certain Personal Data to servers or service providers located outside Indonesia. In all cases where such transfers occur, 1121ot ensures that:

• The recipient jurisdiction provides an adequate level of data protection as recognized by applicable standards, or
• Appropriate contractual safeguards — including standard data protection clauses — are in place between 1121ot and the receiving party, and
• The transfer is limited to the minimum data necessary for the specific processing purpose, and the receiving party is contractually prohibited from using the data for any purpose beyond what is specified.

14 Policy Amendments

1121ot reserves the right to amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or the services we offer. When material changes are made, we will update the "Last Updated" date at the top of this page and, where practicable, notify registered Players by email. Continued use of the Platform following the publication of an updated Privacy Policy constitutes acceptance of the revised terms. We encourage you to review this page periodically.

15 Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your Personal Data, please contact the 1121ot Data Protection team using the details below:

• Email: [email protected]
• Subject Line: "Privacy Policy Inquiry" or "Data Rights Request"
• Response Time: Within 30 days of receipt for data rights requests; within 3 business days for general privacy inquiries
• Support Hours: 24 hours a day, 7 days a week — covering WIB (UTC+7), WITA (UTC+8), and WIT (UTC+9)

All privacy-related communications are handled with strict confidentiality by our designated Data Protection Officer and compliance team.