Privacy Policy

In this Privacy Policy, the following terms carry the meanings assigned to them below. Terms not defined here carry the same meaning as assigned in the dino89 Terms & Conditions.

• "Personal Data" — Any information relating to an identified or identifiable natural person. 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 that person's identity.
• "Processing" — Any operation or set of operations performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, erasure, or destruction.
• "Controller" — The Company, being the internationally registered entity that operates dino89, which determines the purposes and means of processing Personal Data submitted by members and visitors of the Platform.
• "Data Subject" — The individual to whom the Personal Data relates; in this context, a registered dino89 member or a visitor to the Platform.
• "Third Party" — Any natural or legal person other than the Data Subject, the Controller, or persons who, under the direct authority of the Controller, are authorised to process Personal Data.
• "KYC Data" — Identity documents, selfie verifications, proof-of-address documents, and payment method verification records collected during the Know Your Customer verification process.
• "Cookies" — Small text files placed on a User's device by the Platform for the purposes described in Clause 10.

This Privacy Policy applies to all Personal Data collected by dino89 in connection with your use of the Platform at https://dino89.cam. It applies to:

• Registered account holders — individuals who have completed registration and hold an active or inactive dino89 account.
• Visitors — individuals who access the Platform without registering, to whom cookie and device data collection provisions apply.
• Applicants — individuals who submit enquiries or support requests prior to completing registration.

This policy does not apply to third-party websites, services, or platforms linked to or from dino89 — including game studios such as Pragmatic Play, Evolution Gaming, and Spribe — which operate their own independent privacy practices. dino89 is not responsible for the privacy practices of any third-party service.

By registering an account on dino89, depositing funds, placing bets, or otherwise interacting with the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this policy, you must cease using the Platform and contact support to close your account.

dino89 collects the following categories of Personal Data in connection with platform operation:

dino89 does not collect special categories of Personal Data (such as racial or ethnic origin, health data, religious beliefs, or biometric data beyond that inherent in identity document photographs) unless expressly required by a specific regulatory obligation, in which case the basis for collection will be clearly communicated.

Personal Data is collected through the following channels:

• Direct submission: Data you provide when completing the registration form, submitting KYC documents, initiating a deposit or withdrawal, entering a promotion, or contacting customer support.
• Automated technical collection: Technical Data (IP address, device information, session timestamps) collected automatically by our servers each time you access the Platform. This occurs whether or not you are logged into your account.
• Cookies and trackin g technologies: First-party cookies and similar tracking technologies as described in Clause 10 of this policy.
• Third-party service providers: Technical and fraud-prevention data received from payment processors, identity verification partners, and anti-fraud service providers engaged by dino89 to support platform operations.
• Publicly available sources: In limited circumstances, dino89 may verify information you provide against publicly available records for fraud prevention or KYC compliance purposes.

dino89 processes Personal Data on the following legal bases, depending on the specific purpose for which the data is used:

Where processing is based on legitimate interests, dino89 has conducted a balancing test to confirm that our interests do not override the fundamental rights and freedoms of Data Subjects. Documentation of these assessments is available upon written request.

Personal Data collected by dino89 is used exclusively for the following purposes:

• Account management: Creating, maintaining, and administering your dino89 account, including processing login sessions, account settings changes, and voluntary account closures.
• Payment processing: Verifying and executing deposit and withdrawal transactions through Indonesian bank transfer networks (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja).
• KYC and identity verification: Confirming your identity, age (21+), and Indonesian residency status as required by our licensing obligations.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, account takeovers, bonus abuse, money laundering, and other prohibited conduct as defined in the Terms & Conditions.
• Responsible gaming: Monitoring betting patterns to identify potential problem gambling indicators and applying responsible gaming tools where appropriate. See the Responsible Gaming page for full details.
• Customer support: Responding to support requests, processing complaints, and communicating account-related notifications.
• Legal compliance: Fulfilling reporting and record-keeping obligations imposed by applicable international gaming and financial regulations.
• Marketing communications (consent-based only): Sending promotional offers, bonus announcements, and seasonal campaigns — including promotions tied to Indonesian events such as Idul Fitri, Ramadhan, and Indonesian Independence Day — only to members who have explicitly opted in to receive such communications.
• Platform improvement: Analysing aggregated, anonymised usage data to improve platform performance, user experience, and game content selection.

dino89 does not sell, rent, or trade Personal Data. Data is shared with third parties only in the following limited and controlled circumstances:

• Payment processors and banking partners: Financial Data is shared with the banks and e-wallet providers you use for deposits and withdrawals (e.g., BCA, BRI, Mandiri, OVO, GoPay) solely to execute the requested transactions.
• Identity verification providers: KYC Data is shared with licensed third-party identity verification service providers engaged to support the KYC process. These providers operate under strict data processing agreements and are prohibited from using your data for any purpose other than identity verification on behalf of dino89.
• Game content providers: Limited Technical Data (session identifiers, game history) is shared with content studio providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Pocket Games Soft, Spribe) strictly to render their games within the dino89 Platform environment.
• Fraud prevention and AML service providers: Technical and transactional data may be shared with specialist anti-fraud and anti-money-laundering screening services for the purposes of identifying and preventing financial crime.
• Legal and regulatory authorities: Personal Data will be disclosed to competent legal, regulatory, or law enforcement authorities where dino89 is required to do so by a binding legal obligation, court order, or regulatory direction. Where legally permissible, dino89 will notify the affected Data Subject of such a disclosure.
• Corporate restructuring: In the event of a merger, acquisition, or sale of all or a substantial portion of the Company's assets, Personal Data may be transferred to the successor entity, which will be bound by this Privacy Policy or a materially equivalent replacement policy.

All third parties with whom Personal Data is shared are required to maintain appropriate technical and organisational security measures and to process Personal Data only on documented instructions from dino89.

As an internationally operated platform, dino89 may transfer Personal Data to servers or service providers located outside of Indonesia. Such transfers occur to the extent necessary to deliver platform services, process payments, conduct KYC verification, and maintain platform security infrastructure.

Wherever Personal Data is transferred internationally, dino89 implements appropriate safeguards to ensure that the transferred data receives a level of protection equivalent to that provided under internationally recognised data protection standards. Safeguards employed include:

• Data processing agreements with recipient entities that impose contractual data protection obligations equivalent to those binding on dino89.
• Transfer of data only to jurisdictions with recognised adequate data protection frameworks, or to specific certified recipients within such jurisdictions.
• End-to-end encryption of data in transit for all cross-border transfers involving Personal Data or KYC documentation.

You may request further information regarding the specific safeguards applicable to cross-border data transfers affecting your Personal Data by contacting the support team using the details in Clause 15.

dino89 retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or for as long as required by applicable law or regulatory obligation. The following retention periods apply as a general guide:

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be associated with any identifiable individual. Anonymised data may be retained indefinitely for statistical and analytical purposes.

dino89 uses first-party cookies and similar tracking technologies to operate the Platform effectively, maintain your login session, and analyse aggregate usage patterns. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These cookies maintain your authenticated session, store your language and currency preferences, and enable the bet slip and deposit flow to operate correctly. They cannot be disabled without breaking core platform functionality.
• Functional Cookies: Store preferences you have set — such as your preferred game lobby view or notification settings — to personalise your experience across visits. These cookies do not track your activity on other websites.
• Analytics Cookies: Collect aggregated, anonymised data about how visitors interact with the Platform (pages visited, time on page, error events). This data is used solely to improve platform performance and user experience. No personally identifiable information is recorded in analytics cookies.
• Fraud Prevention Cookies: Used to detect and flag unusual or potentially fraudulent device behaviour, including account takeover attempts and automated bot traffic. These cookies are necessary for platform security and cannot be disabled.

dino89 does not deploy third-party advertising cookies, retargeting pixels, or social media tracking scripts. Your Platform activity is not shared with any advertising network or social media platform through cookie technology.

Most browsers allow you to manage cookie preferences through their settings. Disabling strictly necessary or fraud prevention cookies will impair your ability to use the Platform. dino89 does not respond to browser-level "Do Not Track" signals, as no industry standard for such signals has been established.

dino89 implements a layered set of technical and organisational security measures designed to protect Personal Data against unauthorised access, disclosure, alteration, loss, or destruction. Key measures include:

• TLS/SSL Encryption: All data transmitted between your device and our servers is protected by Transport Layer Security (TLS 1.2 or higher). The padlock icon in your browser confirms an active encrypted connection.
• AES-256 Encryption at Rest: Sensitive data stored within our infrastructure — including KYC documents, payment details, and identity records — is encrypted at rest using AES-256, the same standard used by major international financial institutions.
• Access Controls: Internal access to Personal Data is governed by a strict role-based access control (RBAC) model. Only staff members who require access to specific data categories to perform their designated functions are granted that access.
• Two-Factor Authentication: Administrative access to systems containing Personal Data requires multi-factor authentication. Members are strongly encouraged to enable two-factor authentication on their own accounts.
• Regular Security Audits: The Platform undergoes regular independent security assessments and penetration testing to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: dino89 maintains a documented data breach response procedure. In the event of a breach that poses a risk to your rights and freedoms, affected members will be notified without undue delay and provided with guidance on protective steps to take.

As a Data Subject, you hold the following rights in relation to your Personal Data held by dino89. Rights may be exercised by contacting the support team using the details set out in Clause 15. dino89 will respond to all verified rights requests within 30 calendar days of receipt.

dino89 does not charge a fee for exercising any data right. Where a request is manifestly unfounded or excessive, dino89 may charge a reasonable administrative fee or decline to act on the request, providing written reasons for the decision within the standard response period.

The dino89 Platform is strictly restricted to adults aged 21 years and over. dino89 does not knowingly collect Personal Data from any person under the age of 21. Age verification controls are applied during registration and KYC, and any account found to belong to a person under 21 is permanently closed in accordance with the Terms & Conditions.

If you believe that dino89 has inadvertently collected Personal Data belonging to a person under 21, please contact us immediately using the details in Clause 15. Upon receiving such a notification, dino89 will take prompt steps to verify the claim, close the relevant account, and permanently delete all associated Personal Data from our systems.

dino89 reserves the right to update or amend this Privacy Policy at any time to reflect changes in platform operations, applicable law, regulatory requirements, or data processing practices. The version number and "Last Updated" date at the top of this page indicate the currently effective version.

Material changes to this Privacy Policy — such as the introduction of a new purpose for processing, a new category of data collected, or a new category of third-party recipient — will be communicated to registered account holders via the email address on record at least 14 calendar days before the change takes effect.

Non-material changes (including corrections of typographical errors, formatting adjustments, or clarifications that do not alter the substance of any clause) may be made without advance notice and will take effect upon publication. Your continued use of the Platform following the effective date of any amendment constitutes acceptance of the revised Privacy Policy.

Prior versions of this Privacy Policy are archived and available upon written request submitted to the email address listed in Clause 15.

For all data protection enquiries, rights requests, or complaints regarding dino89's handling of your Personal Data, please contact the customer support team using the details below. All data-related requests should be submitted in writing and include your full registered name, account email address, and a clear description of your request.

If you are not satisfied with dino89's response to a data protection complaint, or if you believe that your data rights have not been upheld, you have the right to escalate your complaint to the relevant supervisory authority in your jurisdiction. dino89 will cooperate fully with any supervisory authority investigation and will not penalise any Data Subject for exercising their right to complain.

For questions about responsible gaming, self-exclusion, or deposit limits — which involve processing of your Personal Data under the responsible gaming framework — please visit the Responsible Gaming page or raise the matter directly with the support team. Responsible gaming requests are treated as high priority and actioned within 24 hours.