Privacy Policy — hunggo Data Protection

1 Introduction

hunggo operates an international-standard online betting and gaming platform accessible at https://hunggo.cam, serving English-preference players across Indonesia — from Jakarta to Bali, from Surabaya to Medan. Our platform offers sports betting, live casino, togel (Indonesia's traditional numbers lottery), and a broad slot library, all denominated in Indonesian Rupiah (IDR).

As a platform that handles financial transactions, personal identification documents, and sensitive account data, we recognize that privacy and data security are fundamental to the trust Members place in us. This Privacy Policy sets out, with full transparency, the categories of personal data we collect, the purposes for which that data is processed, and the technical and organizational measures we employ to keep it safe.

hunggo is the data controller for all personal data collected through the platform. We are committed to processing personal data in a manner that is lawful, fair, transparent, and limited to what is genuinely necessary for the purposes described in this policy.

2 Definitions

The following terms carry the meanings set out below throughout this Privacy Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person ("Data Subject"). An identifiable person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data, or one or more factors specific to their physical, economic, or digital identity.
• "Processing" means any operation performed on personal data, including collection, recording, storage, adaptation, retrieval, use, disclosure, transmission, restriction, erasure, or destruction.
• "Data Controller" means hunggo, the entity that determines the purposes and means of processing personal data collected through the platform.
• "Data Processor" means any third-party service provider that processes personal data on hunggo's behalf, pursuant to a written data processing agreement.
• "Member" means any individual who has completed account registration on the hunggo platform.
• "Visitor" means any individual who browses the hunggo website without completing account registration.
• "KYC" (Know Your Customer) means the identity verification process through which hunggo confirms a Member's age, identity, and source of funds.
• "Consent" means a freely given, specific, informed, and unambiguous indication of the Data Subject's agreement to the processing of their personal data for one or more specific purposes.

3 Data We Collect

hunggo collects personal data across several categories, depending on how you interact with the platform. The table below summarizes the categories and specific data points we may collect:

4 How We Collect Data

Personal data is collected through the following channels:

• Direct Submission: Information you voluntarily provide during account registration, KYC document upload, deposit or withdrawal requests, and contact with customer support.
• Automated Technical Collection: Data collected automatically when you access the platform, including IP addresses, device fingerprinting data, browser information, and session logs generated by our web servers and analytics infrastructure.
• Payment Processors: Confirmation data received from Indonesian banking and e-wallet partners (BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, LinkAja) relating to completed deposit and withdrawal transactions.
• Third-Party Verification Services: Identity verification outcomes provided by contracted KYC verification service providers who pr ocess your submitted identification documents on our behalf under strict data processing agreements.
• Cookies and Tracking Technologies: Data collected via cookies, web beacons, and similar technologies as described in Section 11 of this policy.
• Fraud Prevention Tools: Risk signals and device reputation data provided by third-party fraud detection partners to protect the integrity of the platform and its Members.

5 Legal Basis for Processing

hunggo processes personal data only where a valid legal basis exists. The legal bases applicable to our processing activities are as follows:

• Contractual Necessity: Processing that is necessary to perform our contractual obligations to you as a Member — including account creation, identity verification, payment processing, game delivery, and customer support.
• Legal Obligation: Processing required to comply with applicable legal and regulatory requirements, including anti-money-laundering (AML) obligations, fraud prevention mandates, and record-keeping requirements imposed by international gaming compliance standards.
• Legitimate Interests: Processing carried out in pursuit of hunggo's legitimate business interests, provided those interests are not overridden by your fundamental rights and freedoms. Legitimate interests include fraud detection, platform security, product improvement, and responsible gaming monitoring.
• Consent: Processing based on your explicit, informed consent — primarily in the context of optional marketing communications. Where consent is the legal basis, you retain the right to withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 How We Use Your Data

The personal data we collect is used exclusively for the following purposes:

• Account Management: Creating and maintaining your Member account, processing login authentication, and enabling account self-service functions (deposit limits, self-exclusion, account closure).
• Identity Verification (KYC): Verifying that you meet the eligibility requirements — including the mandatory minimum age of 21 years — before activating withdrawal privileges on your account.
• Payment Processing: Facilitating deposits and withdrawals through your chosen Indonesian banking or e-wallet channel, reconciling transaction records, and investigating payment disputes.
• Customer Support: Responding to your enquiries, resolving complaints, and maintaining records of support interactions for quality assurance and dispute resolution purposes.
• Responsible Gaming: Monitoring wagering patterns to identify indicators of problem gambling behavior and triggering appropriate safeguarding interventions, such as deposit limit reviews or self-exclusion notices, in line with our Responsible Gaming commitments.
• Fraud Prevention & Security: Detecting, investigating, and preventing unauthorized access, multi-accounting, money laundering, bonus abuse, and other prohibited conduct as defined in our Terms & Conditions.
• Platform Improvement: Analyzing aggregated, anonymized usage data to identify technical issues, improve user experience, and develop new features. Individual-level data is never used for product analytics without appropriate anonymization.
• Legal Compliance: Meeting reporting and record-keeping obligations required under applicable anti-money-laundering, counter-terrorism financing, and international gaming compliance frameworks.
• Marketing Communications: Sending promotional offers, bonus announcements, and platform news to Members who have opted in to receive such communications. See Section 14 for your opt-out rights.

7 Data Sharing & Disclosure

hunggo does not sell, rent, or trade your personal data to any third party for their own commercial purposes. Data is shared only in the limited circumstances described below:

• Payment Partners: Your name, bank account or e-wallet identifier, and transaction amount are shared with the relevant Indonesian payment processor (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, LinkAja, CIMB Niaga) solely for the purpose of completing your requested deposit or withdrawal transaction.
• KYC Verification Providers: Identity documents and personal identifiers are shared with contracted identity verification partners to facilitate KYC processing. These partners operate under binding data processing agreements and may not use the data for any purpose beyond verification.
• Fraud Prevention Services: Technical identifiers (IP address, device fingerprint, risk scores) are shared with third-party fraud detection providers to identify and prevent abuse of the platform.
• Game Content Providers: Your username and session token are passed to licensed game studios (including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft) to enable game session launch and result recording. These providers do not receive your full identity or financial data.
• Legal and Regulatory Disclosure: Personal data may be disclosed to law enforcement agencies, regulatory bodies, or courts where hunggo is legally required to do so by a valid court order, subpoena, or regulatory directive. hunggo will notify affected Members of such disclosures to the extent permitted by law.
• Business Transfers: In the event of a merger, acquisition, or sale of substantially all assets of hunggo, Member personal data may be transferred to the acquiring entity, subject to equivalent privacy protections. Members will be notified of any such transfer with reasonable advance notice.

8 International Data Transfers

As an internationally operating platform serving Members primarily located in Indonesia, some of the personal data we collect may be transferred to, stored on, or processed by systems located outside of Indonesia. This may occur where our contracted data processors — such as cloud infrastructure providers or KYC verification partners — operate server infrastructure in other jurisdictions.

Where personal data is transferred internationally, hunggo ensures that adequate safeguards are in place to protect that data to a standard equivalent to the protections described in this Privacy Policy. Such safeguards include:

• Contractual data protection clauses incorporated into all data processing agreements with international service providers.
• Transfer only to jurisdictions or service providers that maintain data protection standards recognized as adequate under relevant international frameworks.
• Technical measures including end-to-end encryption of data in transit and at rest, regardless of storage location.

9 Data Retention

hunggo retains personal data only for as long as is necessary to fulfill the purposes described in this policy, or as required by applicable legal and regulatory obligations. The following retention guidelines apply:

• Active Account Data: Retained for the full duration of your account's active status, plus a minimum of five (5) years following account closure, to satisfy AML record-keeping requirements and to handle any post-closure disputes or regulatory enquiries.
• KYC Documentation: Retained for a minimum of five (5) years from the date of account closure, consistent with international anti-money-laundering record-keeping standards.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in accordance with financial compliance requirements.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, for dispute resolution and quality assurance purposes.
• Technical and Log Data: Retained for a maximum of thirteen (13) months from the date of collection, after which it is anonymized or deleted.
• Marketing Consent Records: Retained for three (3) years from the date of the last consent or opt-out action, as evidence of lawful marketing activity.

Upon expiry of the applicable retention period, personal data is either securely deleted or anonymized such that it can no longer be associated with any identifiable individual.

10 Security Measures

hunggo employs a layered security architecture to protect Member personal data against unauthorized access, accidental loss, destruction, and alteration. Our technical and organizational security measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your browser or app and our servers is encrypted using industry-standard TLS protocols, ensuring that data in transit cannot be intercepted.
• Encrypted Data Storage: Sensitive data fields — including passwords (stored as salted hashes), financial account identifiers, and KYC document files — are encrypted at rest using AES-256 encryption.
• Access Controls: Access to Member personal data is restricted on a strict need-to-know basis. All internal access is logged, authenticated via multi-factor authentication, and subject to periodic access review audits.
• Intrusion Detection and Prevention: Our infrastructure is monitored continuously by automated intrusion detection systems, with 24/7 security operations oversight.
• Vulnerability Management: Regular penetration testing and vulnerability assessments are conducted by independent security specialists to identify and remediate potential weaknesses before they can be exploited.
• Incident Response: In the event of a personal data breach that poses a risk to Member rights and freedoms, hunggo will notify affected Members within 72 hours of becoming aware of the breach, providing details of the nature of the breach, the data affected, and the steps being taken to mitigate impact.

11 Cookies & Tracking Technologies

hunggo uses cookies and similar tracking technologies to operate the platform, enhance your experience, and gather aggregated usage analytics. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the platform to function correctly. These cookies manage your authenticated session, maintain your login state, and remember your active wagering selections. They cannot be disabled without impairing core platform functionality.
• Performance & Analytics Cookies: Collect anonymized data on how visitors interact with the platform — including pages visited, time on site, and error encounters — to help us improve performance and user experience. No individually identifiable data is collected via these cookies.
• Functional Cookies: Remember your preferences such as language settings, display options, and responsible gaming configurations, so that you do not need to reset them on each visit.
• Fraud Prevention Cookies: Assist our security systems in identifying suspicious device behavior, multiple-account patterns, and bot activity that could harm the platform or its Members.

hunggo does not use advertising or behavioral targeting cookies that track your activity across third-party websites. You may manage your cookie preferences through your browser settings; however, disabling strictly necessary cookies will impair your ability to use the platform.

12 Your Rights

As a Member of the hunggo platform, you hold the following rights in relation to your personal data. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request" and your registered email address:

• Right of Access: You may request a copy of all personal data held about you by hunggo, together with information about how it is being processed.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you may request that it be corrected or updated. For identity data, a KYC re-verification process may be required.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (and no other legal basis applies), or where the data has been processed unlawfully. This right is subject to our legal retention obligations outlined in Section 9.
• Right to Restriction of Processing: You may request that we restrict processing of your personal data in circumstances where you contest its accuracy, where processing is unlawful, or where we no longer need the data but you require it for a legal claim.
• Right to Data Portability: You may request a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format, for transfer to another controller.
• Right to Object: You may object to processing of your personal data where the legal basis is legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• 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 prior processing.

hunggo aims to respond to all data rights requests within 30 calendar days. Where a request is complex or involves a large volume of data, we may extend this period by a further 60 days, in which case we will notify you of the extension and the reasons for it.

13 Protection of Minors

The hunggo platform is strictly intended for adults aged 21 years and over. We do not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory component of the KYC process, and any account found to belong to a person under 21 will be immediately suspended and all associated data will be handled in accordance with our legal obligations.

If you are a parent or guardian and believe that a minor under your care has provided personal data to hunggo without your consent, please contact us immediately at [email protected]. We will investigate the matter promptly and, where confirmed, delete the minor's data and close the associated account.

14 Marketing Communications

With your explicit consent, hunggo may send you marketing communications relating to platform promotions, new game launches, bonus offers, and seasonal campaigns relevant to the Indonesian market (including events such as Idul Fitri, Ramadhan, Indonesian Independence Day, and Chinese New Year / Imlek). These communications are delivered via email to your registered address.

You may opt out of marketing communications at any time by:

• Clicking the "Unsubscribe" link included at the footer of every marketing email we send.
• Updating your communication preferences within your account settings dashboard.
• Contacting us directly at [email protected] with the subject line "Marketing Opt-Out".

Opt-out requests will be processed within 5 business days. Please note that opting out of marketing communications does not affect transactional communications — we will continue to send essential account notifications (deposit confirmations, withdrawal updates, security alerts, KYC requests) regardless of your marketing preference.

15 Third-Party Services

The hunggo platform integrates with third-party service providers to deliver payment processing, game content, security monitoring, and analytics functions. While we select all providers with care and bind them to strict data protection obligations, hunggo is not responsible for the independent privacy practices of third-party entities.

Third-party services integrated into the platform include game content providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft), Indonesian payment gateways (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, LinkAja), and fraud prevention and KYC verification partners. Each of these providers maintains their own privacy policy governing their independent data practices.

The hunggo website does not contain links to external third-party websites. In the event that our platform is accessed through a third-party referral source, this Privacy Policy applies exclusively to data processing conducted by hunggo on the hunggo platform.

16 Policy Amendments

hunggo reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or operational requirements. Where amendments are material — meaning they meaningfully affect how we collect or use your personal data — we will provide at least 7 days' advance notice by email to your registered address and via a prominent notice on the platform.

The "Last Reviewed" date displayed at the top of this page and in the page hero section indicates when the current version of this policy was published. We recommend reviewing this page periodically to stay informed of any updates. Your continued use of the platform following the publication of an updated Privacy Policy constitutes your acknowledgment of the revised terms.

Previous versions of this Privacy Policy are archived and available upon request by contacting [email protected].

17 Contact & Data Protection Officer

If you have any questions, concerns, or complaints regarding this Privacy Policy or the manner in which hunggo processes your personal data, please contact our dedicated privacy team. We are committed to resolving all privacy-related enquiries fairly and transparently.

• General Privacy Enquiries: [email protected] (Subject: "Privacy Enquiry")
• Data Rights Requests: [email protected] (Subject: "Data Rights Request")
• Data Breach Notifications: [email protected] (Subject: "Security Concern")
• Marketing Opt-Out: [email protected] (Subject: "Marketing Opt-Out")

Our privacy team operates on a 24/7 basis (WIB timezone reference) and aims to acknowledge all privacy-related correspondence within 24 hours and to provide a substantive response within 30 calendar days.