Privacy Policy

1. Introduction

atm178 ("we", "us", "our", or the "Platform") is committed to protecting the privacy and personal data of every player who uses our online gaming services at atm178.cam. This Privacy Policy sets out the legal basis on which we collect, store, use, and disclose personal information provided by users ("you", "your") in connection with the creation and management of a gaming account on atm178.

This policy applies to all personal data collected through atm178.cam, our customer support channels, our live-chat system, and any communications you initiate with us via email or other messaging platforms. It does not cover third-party websites or services that may be linked from our platform.

2. Definitions

For the purposes of this Privacy Policy, the following terms carry the meanings set out below:

• "Personal Data" — any information that can be used, alone or in combination with other data, to identify a specific individual. This includes name, email address, phone number, financial account details, and IP address.
• "Processing" — any operation performed on personal data, including collection, storage, retrieval, use, disclosure, or deletion.
• "Data Controller" — atm178, the entity that determines the purposes and means of processing your personal data.
• "Data Processor" — a third party that processes personal data on behalf of atm178, such as KYC verification providers or payment processors.
• "KYC" (Know Your Customer) — the regulatory identity verification process applied to all players before they can make withdrawals.
• "Cookies" — small text files placed on your device by our website to store session information and preferences.
• "AML" — Anti-Money Laundering regulations applicable to financial services and gaming operations.

3. Personal Data We Collect

atm178 collects the following categories of personal data, depending on the nature of your interaction with the platform:

3.1 Registration and Account Data

• Full legal name
• Date of birth (to confirm you are 21 years of age or older)
• Email address
• Mobile phone number
• Residential address in Indonesia (city, province, postal code)
• Preferred username and encrypted password

3.2 Identity Verification (KYC) Data

• Government-issued photo ID (Indonesian KTP, passport, or driver's license — front and back)
• Selfie photograph with ID document
• Proof of residential address (utility bill, bank statement, or official correspondence dated within the last 3 months)
• Source-of-funds declaration (for high-volume players, where required by AML procedures)

3.3 Financial and Transaction Data

• Bank account details (account holder name, account number, bank name — e.g., BCA, BRI, BNI, Mandiri, CIMB Niaga)
• E-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja — registered phone number or account ID)
• Deposit and withdrawal amounts and timestamps
• Betting history and game session records
• Bonus claims and wagering activity

3.4 Technical and Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser version
• Session duration and pages visited on atm178.cam
• Login timestamps and frequency
• In-game behavior and event logs (for fraud detection and responsible gaming monitoring)

3.5 Communication Data

• Content of live-chat transcripts with our support team
• Email correspondence history
• WhatsApp message records (metadata only for operational purposes)
• Feedback, complaints, and dispute records

4. How We Collect Your Data

atm178 collects personal data through the following channels:

• Direct provision by you: When you complete the registration form, submit KYC documents, initiate a deposit or withdrawal, or contact our support team.
• Automated technical collection: Via cookies, server logs, and analytics tools that record your device and usage data when you visit atm178.cam.
• Third-party verification services: Identity verification providers may return enriched data (e.g., database-matched identity confirmation) as part of the KYC process.
• Payment processors: Transaction confirmation data is received from Indonesian banks and e-wallet providers when you make a deposit or withdrawal.

5. Purpose of Processing Your Data

We use your personal data exclusively for the following purposes:

Purpose	Data Categories Used
Account creation and authentication	Registration data, device/technical data
Identity verification and age confirmation (KYC)	KYC documents, registration data
Processing deposits and withdrawals	Financial data, KYC data
Fraud detection and AML compliance	All categories including behavioral/usage data
Responsible gaming monitoring	Betting history, session data, communication data
Customer support provision	Communication data, account data
Platform improvement and analytics	Anonymized or aggregated usage data
Promotional communications (with consent)	Email, phone number, gaming preferences

6. Legal Basis for Processing

atm178 processes your personal data on one or more of the following legal grounds:

• Contractual necessity: Processing required to fulfill our obligations to you under the account agreement — including managing your account, processing bets, and handling payments.
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML obligations, identity verification requirements, and financial record-keeping mandates.
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and improving our services — provided these interests are not overridden by your privacy rights.
• Consent: Where you have given explicit, informed consent for specific processing activities, such as receiving promotional communications. You may withdraw this consent at any time by contacting our support team.

7. Sharing Your Personal Data

atm178 does not sell, rent, or trade your personal data to any third party. We may, however, share your data with the following categories of recipients under strict confidentiality obligations:

7.1 Service Providers and Data Processors

We engage carefully vetted third-party processors to assist in delivering our services. These include:

• KYC and identity verification providers: To confirm your identity and age in compliance with regulatory requirements.
• Payment processors and banking partners: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to process your financial transactions.
• Fraud detection and cybersecurity services: To identify and prevent unauthorized account access, bonus abuse, and money laundering activity.
• Cloud hosting and infrastructure providers: To store your data securely on servers with appropriate technical safeguards.
• Customer support platform providers: To enable our live-chat and ticketing systems.

All third-party data processors are contractually bound to process your data only on atm178's documented instructions and to maintain confidentiality and security standards consistent with this Privacy Policy.

7.2 Legal and Regulatory Disclosures

atm178 may disclose your personal data to law enforcement agencies, government bodies, or regulatory authorities when required to do so by applicable law, valid legal process, or to protect the rights, property, or safety of atm178, our players, or the public.

7.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or substantially all of atm178's assets, your personal data may be transferred to the acquiring entity. You will be notified via email or a prominent notice on atm178.cam prior to any such transfer taking effect, and you will have the opportunity to close your account if you do not consent to the transfer.

8. Cookies and Tracking Technologies

8.1 What Cookies We Use

atm178 uses the following categories of cookies and similar tracking technologies when you visit atm178.cam:

• Strictly Necessary Cookies: Essential for the website to function. These include session authentication tokens, security cookies, and load-balancing cookies. They cannot be disabled without breaking core site functionality.
• Functional Cookies: Store your preferences such as preferred language, last-visited game category, and display settings to improve your browsing experience on return visits.
• Analytics Cookies: Collect anonymized or aggregated data about how players navigate atm178.cam — pages visited, session duration, and entry/exit points. This data informs platform improvements and is never linked to your individual profile for marketing purposes.
• Security Cookies: Used to detect suspicious login attempts, bot activity, and fraudulent account access patterns.

8.2 Managing Your Cookie Preferences

You can control non-essential cookies through your browser settings. Most modern browsers allow you to block, delete, or receive alerts about cookies. Please note that disabling strictly necessary cookies will impair your ability to log in and use core platform features. Detailed instructions for managing cookies are available in the help documentation of your browser (Chrome, Firefox, Safari, Edge, or Samsung Internet for Android users in Indonesia).

8.3 No Third-Party Advertising Trackers

atm178 does not deploy third-party advertising pixels, cross-site tracking scripts, or social-media retargeting tags on atm178.cam. We do not participate in behavioral advertising networks.

9. Data Retention

atm178 retains your personal data for the following periods, after which data is securely deleted or irreversibly anonymized:

Data Category	Retention Period	Reason
Account registration data	Duration of account + 5 years after closure	Legal and AML obligations
KYC identity documents	Duration of account + 5 years after closure	Regulatory compliance
Financial transaction records	7 years from transaction date	Financial record-keeping requirements
Betting and game history	Duration of account + 2 years after closure	Dispute resolution, responsible gaming
Customer support communications	3 years from last interaction	Quality assurance and dispute records
Technical/usage logs	12 months from collection	Security monitoring and fraud detection
Marketing consent records	Until consent is withdrawn + 1 year	Proof of consent

If you request account closure, atm178 will cease active use of your personal data immediately. Retained data during the post-closure period is held in secure, access-restricted archives solely for the legal and regulatory purposes described above.

10. Data Security Measures

atm178 implements a multi-layered security framework to protect your personal data against unauthorized access, accidental loss, alteration, or disclosure:

• 256-bit SSL/TLS encryption on all data transmitted between your browser and our servers.
• AES-256 encryption at rest for all stored personal data and financial records on our database servers.
• Multi-factor authentication (MFA) available to all players and mandatory for all internal staff accounts with access to player data.
• Role-based access controls (RBAC) ensuring that employees can only access the data categories required for their specific job function.
• Regular security audits and penetration testing conducted by independent cybersecurity specialists.
• Intrusion detection systems (IDS) that monitor for abnormal access patterns and trigger immediate alerts for investigation.
• Incident response plan: In the event of a confirmed data breach affecting your personal data, atm178 will notify affected users within 72 hours of becoming aware of the incident, along with guidance on protective steps you should take.

11. Your Data Rights

As an atm178 player, you have the following rights with respect to your personal data. To exercise any of these rights, contact our support team at [email protected]. We will respond to all verified requests within 30 calendar days.

11.1 Right of Access

You may request a copy of all personal data atm178 holds about you, along with information on how it is used and with whom it has been shared. We will provide this in a clear, structured format.

11.2 Right to Rectification

If any personal data we hold about you is inaccurate or incomplete, you have the right to request correction. For account-level details, you may update some information directly through your account settings.

11.3 Right to Erasure

You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and no other legal basis applies. Please note that certain data (e.g., transaction records and KYC documents) must be retained for the periods specified in Section 9 to comply with legal obligations, and cannot be erased during those retention windows.

11.4 Right to Restrict Processing

In certain circumstances — such as while a dispute about data accuracy is being resolved — you may request that atm178 temporarily suspend active processing of your data. Data subject to a restriction will be stored but not actively used.

11.5 Right to Data Portability

Where processing is based on your consent or on a contractual relationship, and is carried out by automated means, you may request that atm178 provide your personal data in a machine-readable format (JSON or CSV) so that it can be transferred to another service provider.

11.6 Right to Object

You may object at any time to processing based on atm178's legitimate interests, including profiling conducted for fraud detection or responsible gaming monitoring. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.

11.7 Withdrawal of Marketing Consent

If you have consented to receive promotional communications from atm178, you may withdraw that consent at any time by contacting our support team or using the unsubscribe link in any marketing email. Withdrawal of marketing consent does not affect the lawfulness of any processing carried out prior to withdrawal.

12. Minors and Age Restriction

atm178 services are strictly intended for adults aged 21 years or older. We do not knowingly collect personal data from individuals under the age of 21. If you believe that a minor has provided personal data to atm178, please contact us immediately at [email protected] so that we can investigate and take appropriate action, including account closure and deletion of all associated data.

atm178 applies robust age verification controls during the KYC process specifically to prevent underage participation in online gaming. Any account found to belong to a person under 21 years of age will be immediately suspended, all funds returned (less any bonuses received), and the matter reported to the relevant supervisory authority where legally required.

13. Changes to This Privacy Policy

atm178 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or platform features. When material changes are made:

• The revised policy will be published at atm178.cam/privacy-policy with an updated effective date.
• Registered players will be notified via email to their registered address at least 7 days before the changes take effect.
• For significant changes to the legal basis of processing or to the categories of data shared with third parties, we will seek fresh consent where required by applicable law.

Your continued use of atm178 after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not accept the changes, you must close your account before the effective date.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or atm178's data practices, please reach out to our dedicated Data Privacy team:

• Email:  [email protected]
• Live Chat:  Available 24/7 through your atm178 account dashboard
• WhatsApp Support:  Available 24/7 with Indonesian-speaking agents
• Response Time:  All privacy-related requests are acknowledged within 24 hours and resolved within 30 calendar days