Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how ligagg ("we," "us," or "our") collects, uses, stores, shares, and protects personal information provided by users ("you," "Member") when accessing or using the ligagg platform (the "Platform") at ligagg.cam or any associated mobile application or service.

By registering an account or using any part of the Platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein. If you do not agree with any part of this Policy, you must discontinue use of the Platform immediately.

This Policy applies to all personal data processed by ligagg in connection with Indonesian members and users accessing the Platform from Indonesia. It covers data collected online and through customer support interactions conducted via email, live chat, or WhatsApp.

2. Definitions

For the purposes of this Policy, the following definitions apply:

• "Personal Data" means any information that identifies or could reasonably be used to identify you as an individual, including your name, email address, phone number, date of birth, financial account details, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion.
• "Data Controller" means ligagg, as the entity that determines the purposes and means of processing your Personal Data.
• "Third-Party Processor" means any external company engaged by ligagg to process Personal Data on our behalf, subject to a data processing agreement.
• "KYC" means Know Your Customer — the identity and age verification process required to confirm your eligibility to use the Platform.
• "Cookie" means a small data file stored on your browser or device by the Platform to maintain session state, preference settings, or analytics data.

3. Data We Collect

3.1 Information You Provide Directly

When you register, verify your account, or interact with our support team, we collect the following categories of Personal Data:

• Identity Data: Full legal name, date of birth, gender, and nationality as stated on your government-issued ID.
• Contact Data: Email address, Indonesian mobile phone number, and residential address (city and province).
• Identity Verification Documents: KTP (Indonesian national identity card), passport, or driver's license; proof of address documents such as utility bills or bank statements.
• Financial Data: Bank account details (bank name, account number, account holder name) for BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, or Bank Permata; e-wallet identifiers for OVO, DANA, GoPay, ShopeePay, or LinkAja. We do not store full card numbers or CVVs.
• Account Credentials: Username and encrypted password hash. Passwords are stored using industry-standard one-way hashing; we never store or transmit passwords in plain text.

3.2 Information Collected Automatically

When you use the Platform, we automatically collect certain technical and behavioral data:

• Device and Browser Data: IP address, device type, operating system, browser type and version, screen resolution, and language settings.
• Usage Data: Pages visited, features accessed, bet history, game sessions, session duration, click patterns, and referral URLs.
• Location Data: Approximate geographic location derived from your IP address (city and country level). We do not collect precise GPS coordinates.
• Log Data: Server access logs, error logs, and security event logs associated with your account activity.
• Cookie and Tracking Data: Session identifiers, authentication tokens, and aggregate analytics events. See Section 7 for full cookie details.

3.3 Information from Third Parties

We may receive Personal Data from third parties in the following contexts:

• KYC / Identity Verification Providers: Verification status, document authenticity scores, and age confirmation results from our licensed KYC partners.
• Payment Processors: Transaction confirmation references, payment status codes, and fraud risk scores from bank and e-wallet payment gateways.
• Fraud Prevention Services: Device fingerprint data, risk scores, and flagged activity reports from anti-fraud technology providers.
• Public Databases: Sanctions list screenings (OFAC, EU, UN) and politically exposed persons (PEP) checks to comply with AML obligations.

Data Category	Examples	Collection Method
Identity Data	Full name, date of birth, KTP number	Registration form, KYC upload
Contact Data	Email, phone number, address	Registration form, support contact
Financial Data	Bank account number, e-wallet ID	Deposit/withdrawal requests
Technical Data	IP address, device type, browser	Automated — collected on login
Behavioral Data	Bet history, session duration	Automated — Platform activity
Verification Data	KYC result, document scan	KYC partner (third party)

4. How We Use Your Data

ligagg processes your Personal Data for the following specific purposes:

• Account Management: Creating, maintaining, and securing your Member account; processing login and authentication; enforcing the one-account-per-person rule.
• Identity and Age Verification: Confirming that you are at least 21 years of age and a resident of Indonesia, as required by our licensing obligations and responsible gaming policy.
• Payment Processing: Facilitating deposits and withdrawals via Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, Bank Permata) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja); verifying that payment accounts are registered in your own name.
• Service Delivery: Providing access to sports betting, live casino, slot gacor (high-volatility slot games popular in the Indonesian market), togel (Indonesia's traditional numbers lottery), and all other Platform features.
• Fraud Prevention and Security: Detecting and preventing unauthorized account access, bonus abuse, money laundering, match-fixing, and other prohibited activities described in our Terms & Conditions.
• Legal and Regulatory Compliance: Meeting our obligations under anti-money-laundering (AML) regulations, our international gaming license, sanctions screening requirements, and data protection laws applicable to Indonesian users.
• Customer Support: Responding to your enquiries, resolving disputes, and processing account requests submitted via live chat, email, or WhatsApp.
• Responsible Gaming: Monitoring betting patterns to identify signs of problem gambling; administering self-exclusion requests and deposit limits; sending responsible gaming reminders as required by our licensing obligations.
• Platform Improvement: Analyzing aggregated, anonymized usage data to identify technical issues, optimize Platform performance, and enhance the user experience for Indonesian members.
• Marketing Communications: Sending promotional offers, seasonal bonuses (e.g., Ramadhan specials, Idul Fitri promotions, Indonesian Independence Day offers), and platform updates — only where you have given explicit consent or where a legitimate interest applies. You may opt out of marketing communications at any time by contacting support.

5. Legal Basis for Processing

ligagg processes your Personal Data on the following legal bases, consistent with international data protection standards and Indonesia's Personal Data Protection Law (UU PDP):

• Contractual Necessity: Processing required to perform the contract between you and ligagg — including account registration, bet settlement, payment processing, and customer support.
• Legal Obligation: Processing required to comply with AML regulations, licensing conditions, sanctions screening, and age verification mandates.
• Legitimate Interests: Processing for fraud prevention, Platform security, responsible gaming monitoring, and aggregate analytics — where these interests are not overridden by your fundamental rights.
• Consent: Processing for marketing communications and non-essential cookies — where you have given clear, specific, and informed consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

6.1 Third-Party Service Providers

ligagg shares Personal Data with carefully selected third-party service providers who process data on our behalf under binding contractual obligations. These providers are permitted to use your data only for the specific purpose for which it was shared and are prohibited from further disclosure or commercial use.

Categories of third-party processors engaged by ligagg include:

• Payment Gateway Providers: Indonesian bank transfer facilitators and e-wallet integration partners to process deposits and withdrawals.
• KYC / Identity Verification Providers: Licensed third-party services to verify government-issued identification documents and confirm age eligibility.
• Game Content Providers: Studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft, who receive only the minimum session data required to deliver their game content.
• Cloud Infrastructure Providers: Data center and cloud hosting services that store Platform data on secure, access-controlled servers.
• Fraud Detection and Cybersecurity Partners: Providers of device fingerprinting, bot detection, and real-time risk scoring services.
• Customer Support Tools: Live chat and helpdesk software providers who process support ticket content in order to facilitate agent responses.

6.2 Legal Disclosure

ligagg may disclose your Personal Data to government authorities, law enforcement agencies, regulatory bodies, or courts when required to do so by applicable law, valid legal process (such as a court order or subpoena), or to protect the rights, property, and safety of ligagg, its members, or the public.

In the event that we are required to disclose your data to an Indonesian authority or a foreign authority under a mutual legal assistance arrangement, we will notify you of the disclosure to the extent permitted by law.

6.3 Business Transfers

In the event of a merger, acquisition, asset sale, or corporate restructuring involving ligagg, your Personal Data may be transferred as part of that transaction. We will provide notice before your Personal Data becomes subject to a materially different privacy policy, and you will have the option to close your account if you do not consent to the transfer.

6.4 What We Do Not Do

ligagg strictly does not:

• Sell, rent, or license your Personal Data to third-party marketers or data brokers.
• Share your Personal Data with social media platforms for behavioral advertising purposes.
• Disclose your data to any party for purposes beyond those stated in this Policy without your prior explicit consent.

7. Cookies and Tracking Technologies

7.1 What Are Cookies?

Cookies are small text files placed on your browser or device when you visit a website. They serve a range of functions — from keeping you logged in during a session, to detecting unusual account activity, to helping us understand how members navigate the Platform.

7.2 Types of Cookies We Use

Cookie Type	Purpose	Duration
Essential / Session	Maintain your login state, authenticate requests, and prevent cross-site request forgery (CSRF)	Session (deleted on browser close)
Functional	Remember your language preference, display settings, and last-visited game category	Up to 90 days
Security / Fraud Detection	Detect bots, identify suspicious login patterns, and flag duplicate account attempts	Up to 12 months
Analytics	Measure aggregate page views, feature usage, and Platform performance (data is anonymized before analysis)	Up to 12 months

7.3 Managing Cookies

You can control or delete cookies through your browser settings at any time. Most modern browsers allow you to block all cookies, accept only first-party cookies, or delete cookies on browser close. Please note that disabling essential cookies will prevent you from logging into your account and using core Platform features. Blocking functional cookies may affect your user experience but will not restrict access to betting services.

ligagg does not use advertising networks, retargeting pixels, or social media tracking cookies. The cookies we deploy are limited to those listed in the table above.

8. Data Retention

ligagg retains your Personal Data for the minimum period necessary to fulfill the purposes described in this Policy. The following retention periods apply:

• Account and Identity Data: Retained for the duration of your active membership, plus 5 years following account closure. Extended retention is required to meet AML record-keeping obligations and to defend against potential legal claims.
• Transaction and Financial Data: Retained for 5 years from the date of each transaction, in accordance with financial record-keeping requirements applicable to licensed gaming operators.
• KYC Documents: Retained for 5 years following account closure or the last transaction, whichever is later.
• Customer Support Records: Retained for 2 years following closure of the support ticket.
• Marketing Consent Records: Retained until you withdraw consent, plus 1 year thereafter as evidence of prior consent status.
• Technical / Log Data: Retained for 12 months on rolling basis, then securely deleted.
• Anonymized Analytics Data: May be retained indefinitely, as it cannot be linked back to any individual.

Upon expiry of the applicable retention period, your Personal Data is securely deleted or anonymized using industry-standard data destruction methods. If you request account closure before the end of a retention period, we will cease active processing of your data but will retain the minimum data set required by law until the retention window expires.

9. Data Security

ligagg implements a comprehensive, multi-layered security framework to protect your Personal Data against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• Transport Encryption: All data transmitted between your device and our servers is protected by TLS 1.2 or higher (256-bit SSL encryption). Our security certificates are issued by a trusted Certificate Authority and renewed continuously.
• At-Rest Encryption: Sensitive data fields — including identity documents, financial account numbers, and KYC results — are encrypted at the database level using AES-256 encryption.
• Access Controls: Internal access to Personal Data is strictly limited on a need-to-know basis. All employees and contractors with data access undergo background screening, sign confidentiality agreements, and are subject to access audits.
• Two-Factor Authentication (2FA): Available for all member accounts and mandatory for administrative access to our internal systems.
• Penetration Testing: Our Platform undergoes regular independent security assessments and penetration tests to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: We maintain a documented data breach response procedure. In the event of a confirmed data breach affecting your Personal Data, we will notify you and relevant authorities within the timeframe required by applicable law.

10. Your Rights

As a data subject, you hold the following rights in relation to your Personal Data processed by ligagg. To exercise any of these rights, contact our Data Protection team at [email protected] with the subject line "Data Rights Request" and your registered account username. We will respond within 14 business days.

• Right of Access: You may request a copy of the Personal Data we hold about you, along with information about how it is being used.
• Right to Rectification: If any of your Personal Data is inaccurate or incomplete, you may request that we correct or update it. Minor updates (phone number, email address) can be made directly in your Account settings.
• 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, where you have withdrawn consent, or where processing is unlawful. This right is subject to retention obligations under applicable law and our licensing conditions.
• Right to Restriction of Processing: You may request that we restrict processing of your data in certain circumstances — for example, while a rectification request is under review.
• Right to Data Portability: Where processing is based on consent or contractual necessity and carried out by automated means, you may request a machine-readable copy of your Personal Data to transfer to another service provider.
• Right to Object: You may object to processing carried out on the basis of legitimate interests, including direct marketing. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing that occurred before withdrawal.

11. Children's Privacy

ligagg strictly prohibits the use of the Platform by individuals under the age of 21. We do not knowingly collect Personal Data from anyone under the age of 21. If we become aware that a minor has registered an account or provided Personal Data, we will immediately close the account, delete all associated data, and forfeit any funds held in that account.

If you are a parent or guardian and believe that a minor in your care has registered with ligagg, please contact us immediately at [email protected] so that we can take appropriate action without delay.

12. Changes to This Policy

ligagg reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. When material changes are made, we will:

• Update the "Last Updated" date at the top of this page.
• Display a prominent notice on the Platform homepage for a minimum of 14 days following the change.
• Send a notification to your registered email address if the changes materially affect your rights or the way we handle sensitive data.

Your continued use of the Platform after the effective date of any revised Policy constitutes acceptance of the updated terms. If you do not agree with the revised Policy, you must close your account before the effective date.

13. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the jurisdiction in which ligagg holds its international gaming license, and with due regard to the data protection principles established under Indonesia's Personal Data Protection Law (Undang-Undang No. 27 Tahun 2022 tentang Pelindungan Data Pribadi — UU PDP).

Any disputes relating to this Policy that cannot be resolved through direct negotiation with our Data Protection team will be subject to the exclusive jurisdiction of the competent courts in our licensing jurisdiction, unless otherwise required by mandatory provisions of Indonesian law.

14. Contact Us

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

• Email: [email protected] — Subject line: "Privacy / Data Rights Request"
• WhatsApp: +62 811 9999 0505 — Available 24/7 (WIB, UTC+7)
• Live Chat: Available directly on the Platform, 24 hours a day, 365 days a year
• Response Time: Data rights requests are handled within 14 business days. General enquiries receive a first response within 2–5 minutes during peak hours.