Privacy Policy

1. Introduction and Scope

This Privacy Policy explains how lok21 ("we," "us," or "our") collects, uses, discloses, and protects personal information from individuals ("you" or "your") who access or use our online gaming platform at lok21.cam and related services (collectively, the "Services"). This policy applies to all personal data we collect through our website, mobile applications, customer support channels, and any other means through which you interact with lok21.

By creating an account with lok21, depositing funds, or using any of 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 any part of this policy, you must discontinue use of our Services immediately.

2. Information We Collect

lok21 collects several categories of personal information to provide, maintain, and improve our Services, comply with legal obligations, and ensure platform security. The types of information we collect include:

2.1 Account Registration Information

When you create a lok21 account, we collect:

• Personal Identifiers: Full legal name, date of birth, gender, and nationality.
• Contact Information: Email address, mobile phone number, and residential address including city, province, and postal code.
• Account Credentials: Username and encrypted password (we store passwords using one-way hashing; we cannot retrieve your original password).
• Preferred Currency: Indonesian Rupiah (IDR) for account transactions.

2.2 Identity Verification Documents (KYC)

To comply with anti-money laundering (AML) regulations and prevent fraud, we collect:

• Government-Issued ID: Scanned copy or photograph of your Indonesian national identity card (KTP) showing your photo, name, date of birth, ID number, and address.
• Proof of Address: Recent utility bill, bank statement, or official correspondence dated within the last three months showing your full name and current residential address.
• Selfie Verification: Photograph of you holding your ID card next to your face to confirm you are the account holder.
• Source of Funds Documentation: In certain circumstances, we may request documentation regarding the source of deposited funds, such as bank statements or employment verification, to comply with AML regulations.

2.3 Financial and Transaction Data

We collect information related to your financial transactions on the platform:

• Payment Information: Bank account details (bank name, account number, account holder name), e-wallet information (OVO, DANA, GoPay account identifiers), and payment method preferences.
• Transaction History: Records of all deposits, withdrawals, wagers, winnings, losses, bonus claims, and other financial activities on your account.
• Transaction Metadata: Date, time, amount, currency, payment method, and transaction status for all financial activities.

2.4 Gaming Activity and Usage Data

We automatically collect information about how you use the lok21 platform:

• Gameplay Data: Games played, bets placed, outcomes, session duration, game preferences, and betting patterns.
• Platform Interaction: Pages visited, features used, buttons clicked, search queries, and navigation paths through the site.
• Device Information: Device type (mobile, tablet, desktop), operating system, browser type and version, screen resolution, and device identifiers.
• Technical Data: IP address, geographic location (city/region level, not precise GPS), internet service provider, connection type, and session timestamps.
• Cookies and Tracking: Data collected through cookies, web beacons, and similar technologies to maintain your session, remember preferences, and analyze site usage (see Section 6 for details).

2.5 Communication Records

When you contact lok21 customer support or communicate with us, we collect:

• Support Inquiries: Content of your messages, chat transcripts, email correspondence, and attachments.
• Feedback and Surveys: Responses to voluntary surveys, feedback forms, and satisfaction ratings.
• Marketing Preferences: Your consent status for receiving promotional emails, SMS messages, and push notifications.

3. How We Use Your Information

lok21 uses the personal information we collect for the following purposes:

3.1 Service Provision and Account Management

• Creating, maintaining, and managing your lok21 account.
• Processing deposits, withdrawals, and other financial transactions.
• Providing access to casino games, sports betting markets, live dealer experiences, and other gaming products.
• Calculating and crediting winnings, applying bonuses, and managing your account balance.
• Responding to your inquiries, support requests, and complaints.
• Sending transactional emails and notifications related to your account activity (deposit confirmations, withdrawal updates, password resets).

3.2 Legal Compliance and Verification

• Verifying your identity and age to ensure you meet the 21+ age requirement and are authorized to use our Services.
• Complying with anti-money laundering (AML) and know-your-customer (KYC) regulations.
• Detecting and preventing fraud, money laundering, underage gambling, and other illegal activities.
• Responding to legal requests, court orders, and regulatory inquiries from Indonesian authorities or international law enforcement agencies.
• Maintaining records required by applicable gambling regulations and financial laws.

3.3 Security and Fraud Prevention

• Monitoring accounts and transactions for suspicious or unusual activity indicative of fraud or security threats.
• Detecting and preventing bonus abuse, multi-accounting, collusion, and other forms of platform exploitation.
• Protecting lok21 and our players from cyberattacks, hacking attempts, and malicious software.
• Investigating disputes, chargebacks, and policy violations.
• Enforcing our Terms and Conditions and other platform policies.

3.4 Platform Improvement and Analytics

• Analyzing usage patterns, game preferences, and player behavior to improve our Services.
• Conducting internal research and data analysis to enhance platform performance, user experience, and game selection.
• Testing new features, products, and services before general release.
• Identifying and fixing technical issues, bugs, and performance bottlenecks.
• Generating aggregated, anonymized statistics and reports for internal business purposes (aggregated data does not identify individual players).

3.5 Marketing and Promotional Communications

With your explicit consent, we may use your contact information to send:

• Promotional emails about new games, bonus offers, tournaments, and special events.
• Personalized recommendations based on your gaming preferences and activity history.
• Newsletters with industry news, platform updates, and responsible gaming tips.
• SMS messages for time-sensitive promotions or urgent account notifications (you must opt-in for SMS marketing).

You may withdraw consent for marketing communications at any time by clicking the "unsubscribe" link in our emails, adjusting your notification preferences in account settings, or contacting customer support. Opting out of marketing does not affect transactional or account-related communications.

4. How We Share Your Information

lok21 does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information in the following limited circumstances:

4.1 Service Providers and Business Partners

We share personal information with trusted third-party service providers who perform services on our behalf, including:

• Payment Processors: Banks, e-wallet providers, and payment gateways (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay) to process deposits and withdrawals.
• Game Providers: Casino game studios (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, etc.) to deliver game content and track gameplay for RTP calculations.
• Identity Verification Services: KYC verification providers to authenticate your identity documents and prevent fraud.
• Cloud Hosting Providers: Secure server infrastructure providers to store data and host the platform.
• Customer Support Tools: Live chat software providers and ticketing systems to manage player inquiries.
• Marketing and Analytics: Email service providers and analytics platforms (only for aggregated, non-personally-identifiable analytics).

All third-party service providers are bound by strict confidentiality agreements and are only permitted to use your information to perform services for lok21. They may not use your data for their own purposes.

4.2 Legal and Regulatory Compliance

We may disclose your personal information if required by law or if we believe in good faith that such disclosure is necessary to:

• Comply with legal obligations, court orders, subpoenas, or regulatory requests from Indonesian authorities or international law enforcement.
• Enforce our Terms and Conditions or other platform policies.
• Protect the rights, property, or safety of lok21, our players, or the public.
• Detect, prevent, or address fraud, security issues, or technical problems.
• Respond to claims that content or activity violates the rights of third parties.

4.3 Business Transfers

In the event that lok21 is involved in a merger, acquisition, asset sale, or bankruptcy proceeding, your personal information may be transferred to the acquiring or successor entity. We will notify you via email and/or prominent notice on our website before your information is transferred and becomes subject to a different privacy policy.

5. Data Retention

lok21 retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Specific retention periods depend on the type of data:

After the applicable retention period expires, we securely delete or anonymize your personal information in accordance with industry best practices. Anonymized data (data that can no longer identify you) may be retained indefinitely for statistical analysis and platform improvement.

6. Cookies and Tracking Technologies

lok21 uses cookies, web beacons, and similar tracking technologies to enhance your experience on our platform. Cookies are small text files stored on your device that help us recognize you, maintain your session, remember your preferences, and analyze how you use our site.

6.1 Types of Cookies We Use

• Essential Cookies: Required for the platform to function properly. These enable core features like user authentication, session management, and security. You cannot opt out of essential cookies.
• Functional Cookies: Remember your preferences, language settings, and account information to provide a personalized experience.
• Analytics Cookies: Collect aggregated, anonymized data about how visitors use our platform to help us improve functionality and user experience.
• Advertising Cookies: Used to deliver relevant promotional content and measure advertising campaign effectiveness (only if you opt in to marketing communications).

6.2 Managing Cookie Preferences

You can control and manage cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or receive alerts when cookies are being sent. Note that disabling essential cookies may prevent you from accessing certain platform features. Refer to your browser's help documentation for instructions on managing cookies.

7. Data Security

lok21 implements comprehensive technical, administrative, and physical security measures to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction:

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS protocols. Sensitive data stored in our databases is encrypted at rest.
• Secure Infrastructure: Our platform is hosted on secure, redundant servers with 24/7 monitoring, firewalls, intrusion detection systems, and regular security audits.
• Access Controls: Personal data is accessible only to authorized personnel who require it for legitimate business purposes. All employees sign confidentiality agreements and receive security training.
• Password Protection: Account passwords are stored using one-way cryptographic hashing algorithms (bcrypt or similar). We cannot retrieve your original password; you must reset it if forgotten.
• Regular Audits: We conduct periodic security assessments, vulnerability scans, and penetration tests to identify and address potential risks.
• Incident Response: In the unlikely event of a data breach, we have an incident response plan to contain the breach, assess impact, and notify affected individuals as required by law.

While we implement robust security measures, no method of transmission or storage is 100% secure. You also play a role in protecting your information by using strong, unique passwords, not sharing your account credentials, and logging out after each session.

8. Your Privacy Rights

Depending on your jurisdiction, you may have certain rights regarding your personal information:

8.1 Right to Access

You have the right to request a copy of the personal information we hold about you. You can access most information directly through your account settings. For additional information, contact our support team.

8.2 Right to Rectification

You can update or correct inaccurate personal information through your account settings. If you cannot update information yourself, contact customer support for assistance.

8.3 Right to Deletion

You may request deletion of your personal information, subject to legal retention requirements. We must retain certain data (transaction records, KYC documents) for regulatory compliance even after account closure. To request deletion, contact [email protected].

8.4 Right to Restriction of Processing

You can request that we limit how we use your personal information in certain circumstances, such as when you contest the accuracy of data or object to processing.

8.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit that data to another service provider.

8.6 Right to Withdraw Consent

Where we process your personal information based on consent (e.g., marketing communications), you may withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

8.7 Right to Object

You have the right to object to processing of your personal information for direct marketing purposes at any time.

To exercise any of these rights, contact us at [email protected] with your request. We will respond within 30 days and may require identity verification before fulfilling your request.

9. Third-Party Links

The lok21 platform may contain links to third-party websites, services, or applications (such as game provider sites or payment processor pages). This Privacy Policy applies only to lok21 services. We are not responsible for the privacy practices of third-party sites. We encourage you to review the privacy policies of any third-party site you visit.

10. Children's Privacy

lok21 services are strictly intended for individuals 21 years of age or older. We do not knowingly collect personal information from anyone under 21. If we become aware that we have inadvertently collected information from a minor, we will immediately delete that information and close the associated account. If you believe a minor has provided personal information to lok21, contact us immediately at [email protected].

11. International Data Transfers

Your personal information may be transferred to and processed in countries other than Indonesia where our servers, service providers, or business partners are located. These countries may have data protection laws different from Indonesian laws. When we transfer data internationally, we implement appropriate safeguards (such as standard contractual clauses) to ensure your information receives adequate protection.

12. Changes to This Privacy Policy

lok21 may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or platform features. When we make material changes, we will notify registered users via email or through a prominent notice on our website at least 7 days before the changes take effect. The "Last Updated" date at the top of this policy indicates when it was most recently revised. Your continued use of lok21 services after changes take effect constitutes acceptance of the revised Privacy Policy.

13. Contact Information

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us:

• Email: [email protected]
• Subject Line: "Privacy Inquiry" or "Data Protection Request"
• Live Chat: Available 24/7 through the platform for immediate assistance
• Response Time: We aim to respond to all privacy-related inquiries within 48 hours