tembet Privacy Policy

1 Introduction

This Privacy Policy governs the processing of personal data by tembet ("we", "us", "our", "the Company") when you access or use our website located at https://tembet.cam and any associated services, mobile applications, or platforms (collectively, "the Platform"). This policy applies to all users, including visitors, registered players, and account holders.

We recognize that trust is earned through transparency and action. This document explains our data practices in clear language and outlines the rights you have over your personal information. If you do not agree with the terms of this Privacy Policy, you should not use the Platform.

2 Data Controller

For the purposes of applicable data protection laws, tembet acts as the data controller for the personal information collected through the Platform. This means we determine the purposes and means of processing your personal data and are responsible for ensuring compliance with data protection regulations.

If you have questions about how your data is handled or wish to exercise your rights, you can reach our data protection team at the contact details provided in Section 14 of this policy.

3 Information We Collect

We collect different types of personal information depending on how you interact with the Platform. The categories of data we collect include:

3.1 Information You Provide Directly

When you register an account, make a deposit, request a withdrawal, or contact customer support, you provide us with information including:

• Account Registration Data: Full legal name, date of birth, email address, mobile phone number, residential address, username, password.
• Identity Verification (KYC) Data: Government-issued photo identification (National ID Card / KTP, passport, driver's license), proof of address (utility bill, bank statement), selfie photos, and other documents required to verify your identity and comply with anti-money laundering regulations.
• Payment Information: Bank account details, e-wallet account information, payment method names, transaction history.
• Communication Data: Messages, emails, live chat transcripts, and phone call records when you contact customer support or respond to surveys.
• Preference Data: Language preference, timezone, communication preferences, responsible gaming settings (deposit limits, self-exclusion requests).

3.2 Information Collected Automatically

When you access the Platform, certain information is collected automatically through cookies and similar technologies:

• Device Information: IP address, browser type and version, operating system, device model, screen resolution, unique device identifiers.
• Usage Data: Pages visited, time spent on pages, links clicked, referring website, session duration, betting patterns, game play history.
• Location Data: Approximate geographic location based on IP address to ensure compliance with geographic restrictions and provide localized services.

3.3 Information from Third Parties

We may receive information about you from third-party sources including:

• Payment processors and financial institutions when processing deposits and withdrawals.
• Identity verification service providers who assist us in KYC compliance.
• Fraud prevention and security services that help us detect suspicious activity.
• Marketing partners if you have consented to receive promotional communications.

4 How We Use Your Personal Data

tembet uses your personal information for the following purposes:

Purpose	Description
Account Management	To create, manage, and maintain your account, including processing your registration and verifying your identity.
Service Delivery	To provide access to betting and gaming services, process your bets, calculate winnings, manage your balance, and deliver the full Platform experience.
Payment Processing	To process deposits, withdrawals, and other financial transactions securely. This includes working with payment processors and banks.
Compliance & Security	To comply with legal and regulatory obligations including anti-money laundering (AML), Know Your Customer (KYC), age verification, and preventing fraud and abuse.
Customer Support	To respond to your inquiries, resolve disputes, provide technical assistance, and improve our support services.
Marketing & Promotions	To send you promotional offers, bonuses, newsletters, and other marketing communications (only with your consent, which you can withdraw at any time).
Responsible Gaming	To implement responsible gaming measures such as deposit limits, self-exclusion, reality checks, and to identify patterns of problematic gambling behavior.
Platform Improvement	To analyze usage patterns, conduct research, test new features, and improve the overall quality, performance, and security of the Platform.
Legal Protection	To enforce our Terms and Conditions, protect our rights and property, investigate violations, and respond to legal requests from authorities.

5 Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform the contract between you and tembet (i.e., to provide the betting and gaming services you request when you create an account and agree to our Terms and Conditions).
• Legal Obligation: Processing is required to comply with legal and regulatory requirements such as anti-money laundering laws, age verification mandates, tax reporting, and licensing conditions.
• Legitimate Interest: Processing is necessary for our legitimate business interests, such as fraud prevention, security, customer support, platform improvement, and internal analytics, provided these interests do not override your fundamental rights.
• Consent: For certain activities such as marketing communications and non-essential cookies, we rely on your explicit consent, which you can withdraw at any time without affecting the lawfulness of processing based on consent before its withdrawal.

6 Sharing Your Personal Data

tembet does not sell your personal information to third parties. However, we may share your data with the following categories of recipients for the purposes described in this policy:

6.1 Service Providers

We work with trusted third-party service providers who perform functions on our behalf, including:

• Payment processors (banks, e-wallet providers, payment gateways) to facilitate deposits and withdrawals.
• Identity verification services to conduct KYC checks and confirm your age and identity.
• Cloud hosting and IT infrastructure providers who maintain our servers and databases.
• Customer support tools and communication platforms.
• Marketing and analytics platforms (only with your consent for marketing purposes).

All service providers are contractually required to handle your data securely and only for the specific purposes we authorize.

6.2 Game Providers

We share necessary information with licensed game providers (such as Evolution Gaming, Pragmatic Play, NetEnt, and others) to enable you to play their games. This typically includes your username, session ID, and bet history for the games you play.

6.3 Legal and Regulatory Authorities

We may disclose your personal data if required by law, court order, or regulatory request, or if we believe disclosure is necessary to comply with legal obligations, protect our rights, prevent fraud, or ensure the safety of our users.

6.4 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal data may be transferred to the acquiring entity as part of the transaction. You will be notified of any such change via email or prominent notice on the Platform.

7 Data Security Measures

tembet takes the security of your personal data seriously and implements industry-standard technical and organizational measures to protect your information from unauthorized access, loss, misuse, or disclosure. Our security practices include:

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL (Secure Socket Layer) technology, the same standard used by major financial institutions.
• Secure Storage: Personal data is stored on secure servers with restricted access. Sensitive information such as passwords is hashed and salted using strong cryptographic algorithms.
• Access Controls: Access to personal data is limited to authorized employees and service providers who require the information to perform their duties. All access is logged and monitored.
• Regular Audits: Our systems undergo regular security audits and penetration testing by independent third-party security firms to identify and address vulnerabilities.
• Fraud Detection: We use automated systems to detect and prevent fraudulent activity, suspicious transactions, and unauthorized account access.

While we take extensive precautions, no method of transmission over the Internet or electronic storage is 100% secure. If you believe your account has been compromised, contact our support team immediately.

8 Data Retention Period

tembet retains your personal data only 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 vary depending on the type of data:

• Account Data: Retained for the duration of your active account and for a period after account closure as required by regulatory obligations (typically 5–7 years for financial transaction records and KYC documents).
• Transaction Records: Retained for at least 7 years to comply with anti-money laundering regulations and tax reporting requirements.
• Communication Records: Customer support transcripts and correspondence are retained for up to 3 years for quality assurance and dispute resolution purposes.
• Marketing Data: If you withdraw consent for marketing communications, we will retain a record of your opt-out preference indefinitely to ensure we do not contact you again.

Once personal data is no longer required, it is securely deleted or anonymized so that it can no longer be associated with you.

9 Your Privacy Rights

Under applicable data protection laws, you have the following rights regarding your personal data:

• Right of Access: You have the right to request a copy of the personal data we hold about you. We will provide this information in a structured, commonly used, and machine-readable format.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You have the right to request deletion of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, or when you withdraw consent. This right is subject to legal retention obligations.
• Right to Restriction: You have the right to request that we restrict the processing of your personal data in certain situations, such as when you contest the accuracy of the data or object to processing.
• Right to Data Portability: You have the right to receive your personal data in a structured format and transmit it to another controller where technically feasible.
• Right to Object: You have the right to object to processing of your personal data where we rely on legitimate interests as the legal basis. You also have an absolute right to object to direct marketing at any time.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to Lodge a Complaint: If you believe we have not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.

To exercise any of these rights, please contact our data protection team using the details provided in Section 14. We will respond to your request within 30 days.

10 Cookies & Tracking Technologies

tembet uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver personalized content. A cookie is a small text file stored on your device that allows us to recognize you on subsequent visits.

10.1 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function properly. These cookies enable core features such as account login, session management, and security. They cannot be disabled.
• Performance Cookies: Collect anonymous information about how visitors use the Platform, such as which pages are visited most often. This helps us improve site performance.
• Functional Cookies: Remember your preferences such as language, timezone, and display settings to provide a more personalized experience.
• Marketing Cookies: Track your browsing activity to deliver targeted advertisements and measure the effectiveness of marketing campaigns. These cookies require your consent.

10.2 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to block or delete cookies. However, disabling essential cookies may affect the functionality of the Platform and prevent you from accessing certain features.

11 International Data Transfers

tembet operates internationally and may transfer your personal data to countries outside of Indonesia for processing and storage. Some of these countries may have data protection laws that differ from those in Indonesia. When we transfer your data internationally, we ensure appropriate safeguards are in place, such as:

• Standard contractual clauses approved by relevant data protection authorities.
• Ensuring that the recipient country has been recognized as providing an adequate level of data protection.
• Implementing additional technical and organizational security measures to protect your data during transfer.

By using the Platform, you acknowledge and consent to the international transfer of your personal data as described in this policy.

12 Protection of Minors

tembet is strictly for users who are at least 21 years of age. We do not knowingly collect, use, or store personal information from individuals under the age of 21. If we become aware that a user is under 21, we will immediately suspend the account, cease processing their data, and delete their personal information from our systems.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately so we can take appropriate action.

13 Changes to This Privacy Policy

tembet reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. When we make material changes, we will notify you by:

• Posting the updated policy on this page with a revised "Last Updated" date.
• Sending an email notification to your registered email address if the changes materially affect how we use or protect your data.
• Displaying a prominent notice on the Platform when you log in.

Your continued use of the Platform after changes are posted constitutes your acceptance of the updated Privacy Policy. We encourage you to review this policy periodically to stay informed about how we protect your information.

14 Contact Our Data Protection Team

If you have questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact our data protection team:

• Email: [email protected] (Subject line: "Data Privacy Inquiry")
• Live Chat: Available 24/7 via the Platform
• WhatsApp: Available 24/7 (link provided on the Platform)

We will respond to all privacy-related inquiries within 30 days. If your request is complex or requires additional verification, we will keep you informed of our progress.