Privacy Policy — gan78

In this Privacy Policy, the following terms shall have the meanings set out below unless the context otherwise requires:

• "gan78" / "we" / "us" / "our" — refers to gan78, the operator of the website at https://gan78.club and all associated sub-domains, mobile interfaces, and digital services.
• "Member" / "you" / "your" — any individual who has registered an account on the gan78 platform or who accesses the platform as a guest visitor.
• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, date of birth, contact details, financial information, and device identifiers.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, use, disclosure, transmission, or deletion.
• "Data Controller" — the entity that determines the purposes and means of processing Personal Data. For the purposes of this Policy, gan78 acts as the Data Controller.
• "Data Processor" — any third party that processes Personal Data on behalf of gan78 under a contractual arrangement, such as a KYC verification provider or payment gateway operator.
• "KYC" — Know Your Customer; the identity and age verification process required before a member may withdraw funds or access certain account features.
• "Cookies" — small text files placed on a member's device by the gan78 platform for the purposes of session management, analytics, and personalization.
• "AML/CFT" — Anti-Money Laundering and Counter-Financing of Terrorism compliance measures that obligate gan78 to collect and retain certain member transaction data.

gan78 is the Data Controller responsible for the Personal Data collected through the gan78 platform. As Data Controller, gan78 determines the purposes for which your Personal Data is processed and the means by which that processing is carried out, in accordance with applicable international data protection standards.

Where gan78 engages third-party service providers to carry out processing activities on its behalf — such as identity verification partners, payment processors, and fraud prevention services — those parties act as Data Processors under written agreements that bind them to confidentiality obligations and restrict their use of your data to the specific services they provide to gan78.

gan78 collects only the Personal Data that is necessary for the purposes described in this Privacy Policy. The categories of data we collect are as follows:

gan78 does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric identifiers beyond those strictly required for identity verification (e.g., a photograph on a government-issued ID submitted for KYC purposes).

gan78 collects Personal Data through the following channels:

• Direct Submission: Data you provide voluntarily when creating an account, completing the KYC verification process, initiating deposits or withdrawals, contacting customer support, or responding to promotional surveys.
• Automated Collection: Technical and behavioral data collected automatically through cookies, web beacons, server logs, and similar tracking technologies whenever you access the gan78 platform. This data is collected regardless of whether you are logged into an account.
• Third-Party Sources: Identity verification and fraud-screening data received from licensed KYC partners and payment processors as part of the account verification and transaction monitoring processes. This data is used solely to confirm the accuracy of information you have already provided and to fulfil our AML/CFT obligations.
• Inferred Data: Insights derived from your gaming activity and platform behavior — for example, responsible gaming risk indicators based on session frequency and wagering patterns — used exclusively for player protection and platform personalization purposes.

gan78 processes your Personal Data for the following clearly defined purposes:

• Account Management: To create, maintain, and operate your member account, including authenticating your identity at login and managing your account preferences and security settings.
• Service Delivery: To provide access to the full suite of gan78 products — sportsbook markets, live casino tables, slot games, togel draws, keno — and to process bets, calculate winnings, and settle accounts accurately.
• Payment Processing: To facilitate deposits and withdrawals via Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja) in Indonesian Rupiah (Rp).
• Identity Verification (KYC): To verify your identity and confirm that you meet the minimum age requirement of 21 years, in compliance with our licensing obligations and responsible gaming commitments.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, match-fixing, multi-accounting, and other prohibited conduct as defined in our Terms & Conditions.
• Responsible Gaming Monitoring: To identify behavioral indicators of problem gambling — such as rapidly escalating deposit volumes or extended session durations — and to intervene proactively with responsible gaming tools and support resources.
• Customer Support: To respond to your inquiries, resolve complaints, and improve our support processes based on interaction history and feedback.
• Marketing Communications: Where you have opted in to receive promotional content, to send you personalized offers, bonus notifications, and news about new platform features. You may withdraw this consent at any time via your account settings.
• Legal Compliance: To fulfil our obligations under applicable licensing requirements, AML/CFT regulations, and any lawful request from a competent authority or regulatory body.
• Platform Improvement: To analyze usage patterns and technical performance data in order to develop, test, and refine new platform features and improve the overall user experience.

gan78 relies on the following legal bases for processing your Personal Data, consistent with internationally recognized data protection principles:

• Contractual Necessity: Processing required to perform the contract between you and gan78 — including account creation, transaction processing, bet settlement, and customer support. Without this processing, we would be unable to provide the services you have signed up for.
• Legal Obligation: Processing required to comply with applicable legal and regulatory requirements, including KYC identity verification, AML/CFT transaction monitoring, and record-keeping obligations imposed by our international licensing authority.
• Legitimate Interests: Processing carried out for gan78's legitimate business interests, provided those interests are not overridden by your privacy rights. This includes fraud detection and prevention, platform security monitoring, and the analysis of aggregated usage data for product development. Where we rely on legitimate interests, we conduct a balancing test to confirm that our interests do not disproportionately impact your privacy.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications and the use of non-essential cookies. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

gan78 does not sell, rent, or trade your Personal Data to unaffiliated third parties for their own commercial marketing purposes. Your data is shared only in the following strictly defined circumstances:

• Licensed Service Providers: Third-party vendors engaged by gan78 to perform specific functions, including KYC verification partners, payment gateway operators (supporting transactions via BCA, BRI, BNI, and all other supported banks and e-wallets), cloud infrastructure providers, cybersecurity firms, and fraud analytics platforms. All such providers are bound by data processing agreements that restrict their use of your data to the contracted service only.
• Game Content Providers: Game studios — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft — may receive anonymized or pseudonymized session data necessary for the technical delivery of their games. These providers do not receive your identity or financial data directly.
• Regulatory Authorities: Government agencies, law enforcement bodies, and our international licensing authority, where gan78 is legally required to disclose information — for example, in response to a lawful court order, regulatory investigation, or AML/CFT reporting obligation. gan78 will notify you of any such disclosure where legally permitted to do so.
• Corporate Transactions: In the event of a merger, acquisition, or sale of all or substantially all of gan78's assets, your Personal Data may be transferred to the acquiring entity, subject to the same protections described in this Privacy Policy. We will notify you of any such transfer and provide an opportunity to object where technically feasible.
• With Your Consent: In any other circumstances where you have provided explicit consent to a specific disclosure.

gan78 uses cookies and similar tracking technologies to operate the platform effectively, personalize your experience, and analyze site performance. The following categories of cookies are used:

You may manage your cookie preferences through the cookie settings panel accessible from the platform's footer area. Disabling non-essential cookies will not prevent you from using core platform features but may reduce the personalization of your experience. Note that strictly necessary cookies cannot be disabled without impairing platform functionality.

gan78 does not use cookies to track your activity on third-party websites outside the gan78.club domain.

gan78 retains your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following retention periods apply as general guidelines:

• Account and Identity Data: Retained for the duration of your active membership plus a minimum of five years following account closure, to comply with AML/CFT record-keeping requirements and to support the resolution of any post-closure disputes.
• Financial Transaction Data: Deposit, withdrawal, and bet settlement records are retained for a minimum of five years from the date of the transaction in compliance with applicable financial record-keeping standards.
• KYC Documents: Copies of identity documents submitted during the verification process are retained for a minimum of five years from the date of submission or the date of account closure, whichever is later.
• Customer Support Records: Live chat transcripts and email correspondence are retained for two years from the date of the interaction to support quality assurance and dispute resolution processes.
• Technical and Behavioral Data: Server logs and anonymized analytics data are retained for up to 13 months on a rolling basis, after which they are automatically deleted or permanently anonymized.
• Marketing Preferences: Opt-in records for marketing communications are retained for the duration of your membership or until you withdraw consent, and for two years thereafter as evidence of the original consent.

Upon expiry of the applicable retention period, Personal Data is securely deleted or permanently anonymized in accordance with gan78's data disposal procedures. Where retention is required by a specific legal obligation, data is stored in a restricted archive accessible only to compliance personnel.

gan78 implements a comprehensive suite of technical and organizational security measures designed to protect your Personal Data against unauthorized access, alteration, disclosure, or destruction. Our security infrastructure includes:

• SSL/TLS Encryption: All data transmitted between your device and the gan78 servers is encrypted using industry-standard Transport Layer Security (TLS 1.2 or higher). The padlock icon in your browser's address bar confirms that your connection is secure.
• Encryption at Rest: Sensitive data fields — including financial account details, identity document data, and authentication credentials — are encrypted at rest using AES-256 encryption.
• Access Controls: Access to Personal Data within gan78's systems is restricted on a strict need-to-know basis. Staff with access to member data undergo background screening and receive regular data protection training. Administrative access is protected by multi-factor authentication.
• Intrusion Detection: gan78's infrastructure is monitored 24/7 by automated intrusion detection and prevention systems. Anomalous access patterns trigger immediate alerts to the security operations team.
• Penetration Testing: The gan78 platform undergoes regular independent security audits and penetration testing to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: In the event of a confirmed data security incident that affects your Personal Data, gan78 will notify affected members and the relevant supervisory authority within the timeframes required by applicable law, and will take immediate steps to contain and remediate the breach.

As a member of the gan78 platform, you have the following rights with respect to your Personal Data. gan78 is committed to honoring these rights promptly and without charge in the vast majority of cases:

• Right of Access: You have the right to request a copy of the Personal Data that gan78 holds about you, together with information about how it is being processed. We will respond to access requests within 30 days of receipt.
• Right to Rectification: If any of the Personal Data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You may update basic account information directly from your account settings dashboard at any time.
• Right to Erasure ("Right to Be Forgotten"): You may request the deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent (and no other legal basis applies), or where the data has been processed unlawfully. This right is subject to overriding legal obligations — for example, gan78 is required to retain transaction records for AML/CFT compliance and cannot delete them at a member's request within the mandatory retention period.
• Right to Restriction: You may request that gan78 restrict the processing of your Personal Data in certain circumstances — for example, while the accuracy of the data is under dispute, or while you are awaiting the outcome of an objection to processing.
• Right to Data Portability: Where processing is based on your consent or on contractual necessity, and is carried out by automated means, you have the right to receive your Personal Data in a structured, commonly used, machine-readable format, or to request that it be transmitted directly to another controller where technically feasible.
• Right to Object: You have the right to object to the processing of your Personal Data where gan78 relies on legitimate interests as its legal basis, unless gan78 can demonstrate compelling legitimate grounds that override your interests or the processing is necessary for the establishment, exercise, or defense of legal claims.
• Right to Withdraw Consent: Where processing is based on your consent — particularly for marketing communications and non-essential cookies — you may withdraw that consent at any time via your account settings or by contacting our support team. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of these rights, please contact our Data Protection team via live chat or by email at [email protected]. We may be required to verify your identity before processing your request. Where a request is manifestly unfounded or excessive, gan78 reserves the right to charge a reasonable administrative fee or to decline the request, with a written explanation provided.

The gan78 platform is strictly intended for adults aged 21 years and over. gan78 does not knowingly collect Personal Data from individuals under the age of 21. All registration applications are subject to automated and manual age verification checks, and any account found to have been created by a person below the minimum age will be immediately suspended and all associated data will be deleted in accordance with our data disposal procedures.

The gan78 platform may, from time to time, contain references to or integrations with third-party services — such as game content iframes from licensed studios (Pragmatic Play, Evolution Gaming, etc.) or payment gateway interfaces operated by Indonesian banks and e-wallet providers. These third-party services operate under their own privacy policies, which are independent of this document.

gan78 does not control the data collection practices of third-party services embedded within or linked from the platform, and accepts no responsibility for their privacy practices. We encourage you to review the privacy policies of any third-party service you interact with. All game studios integrated into the gan78 platform are selected in part on the basis of their data protection track record and contractual commitments to member privacy.

gan78 reserves the right to amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. Material changes — those that significantly affect your rights or the way we use your Personal Data — will be communicated to you via email to your registered account address and by a prominent notice on the platform's homepage, no less than seven days before the effective date of the change.

Minor amendments — such as corrections of typographical errors, clarifications that do not materially alter the substance of the Policy, or updates to contact information — may be made without advance notice. The "Last Updated" date at the top of this document will be revised to reflect the date of the most recent change in all cases.

Your continued use of the gan78 platform following the effective date of any amendment to this Privacy Policy constitutes your acknowledgment and acceptance of the updated Policy. If you do not agree to the revised Policy, you should close your account and withdraw any remaining balance before the effective date.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data, please contact the gan78 Data Protection team through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week via the live chat widget on the gan78 platform. Native Indonesian-speaking agents are available at all times. Average first-response time is under two minutes.
• Email: [email protected] — please use the subject line "Privacy Request" and include your registered username to help us respond efficiently. Allow up to 24 hours during peak periods.

We aim to acknowledge all privacy-related requests within 48 hours and to resolve them fully within 30 calendar days of receipt. 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 within the initial 30-day period.