hoki62 Privacy Policy

1 Introduction

hoki62 ("we", "us", "our") operates the online betting and casino platform accessible at https://hoki62.club. We are committed to protecting the privacy and personal data of every player ("you", "your") who accesses, registers on, or interacts with the hoki62 platform in any capacity.

This Privacy Policy is incorporated by reference into the hoki62 Terms & Conditions and should be read alongside that document. By creating an account or using any hoki62 service, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

hoki62 serves players primarily located in Indonesia, including major cities such as Jakarta, Surabaya, Bandung, Medan, Bali, Semarang, and Makassar. We process personal data in a manner consistent with internationally recognised data protection principles, including purpose limitation, data minimisation, accuracy, storage limitation, integrity, and confidentiality.

2 Definitions

• "Personal Data" — any information that identifies or can reasonably be used to identify a specific individual, including name, national identity number, email address, phone number, IP address, device identifiers, and financial account details.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, transfer, or deletion.
• "Data Controller" — hoki62, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" — any third-party service provider that processes Personal Data on hoki62's behalf, under a formal data processing agreement and bound by equivalent data protection obligations.
• "Consent" — a freely given, specific, informed, and unambiguous indication of your agreement to the processing of your Personal Data for one or more specific purposes.
• "KYC" — Know Your Customer, the identity and age verification process required before certain account functions (particularly withdrawals) are activated.
• "Cookies" — small text files placed on your device by the hoki62 platform to enable functionality, remember preferences, and support analytics.

3 Data We Collect

hoki62 collects personal data across several categories, each collected for a specific and legitimate purpose:

Category	Examples	When Collected
Identity Data	Full legal name, date of birth, nationality, Indonesian KTP number or passport number	Registration & KYC verification
Contact Data	Email address, phone number, residential address	Registration
Financial Data	Bank account name and number (BCA, BRI, BNI, Mandiri, CIMB Niaga), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja)	Deposit & withdrawal setup
Transaction Data	Deposit history, withdrawal history, bet records, game session logs, bonus usage	Ongoing platform use
Technical Data	IP address, device type, browser type and version, operating system, session timestamps, login history	Every platform visit
Behavioural Data	Pages viewed, games played, features accessed, click patterns, session duration	Every platform visit
Communications Data	Customer support messages, live chat transcripts, email correspondence	When contacting support
Document Data	Copies of identity documents submitted for KYC verification	KYC verification

hoki62 does not collect sensitive categories of personal data such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, or health data unless specifically required by a regulatory obligation and with your explicit consent.

4 How We Collect Data

hoki62 collects personal data through the following channels:

• Direct submission: Information you provide when creating an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in a promotion.
• Automated collection: Technical and behavioural data collected automatically as you navigate the hoki62 platform, via server logs, session tracking, and cookies (see the Cookies section below).
• Third-party sources: Identity verification data obtained from government document databases or third-party KYC service providers when verifying your identity documents. Payment confirmation data received from your bank or e-wallet provider when processing deposits or withdrawals.
• Fraud and security systems: Risk signals and device fingerprint data collected by hoki62's automated fraud prevention systems at the point of login, registration, and transaction.

5 Purposes of Processing

hoki62 processes your personal data for the following specific purposes only:

• Account management: Creating, maintaining, and securing your hoki62 account, including authentication, password recovery, and account preference management.
• Service delivery: Processing deposits and withdrawals in IDR via your chosen payment method, settling bets, crediting winnings, and applying bonuses and promotions to your account balance.
• Identity and age verification (KYC): Confirming that you are at least 21 years of age, that your identity matches the payment methods registered on your account, and that your account is not being used for fraudulent or criminal purposes.
• Legal and regulatory compliance: Meeting our obligations under applicable anti-money laundering (AML) regulations, counter-terrorism financing (CTF) requirements, and any other applicable law or regulatory directive.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, unauthorised account access, multi-accounting, bonus abuse, and other prohibited conduct as described in the hoki62 Terms & Conditions.
• Responsible gaming: Monitoring betting patterns to identify signs of problem gambling, applying deposit limits or self-exclusion settings at your request, and fulfilling our duty-of-care obligations to players showing indicators of gambling harm.
• Customer support: Responding to your enquiries, resolving disputes, and maintaining records of communications for quality assurance and training purposes.
• Platform improvement: Analysing aggregated, anonymised usage data to improve the hoki62 platform, optimise game offerings, and enhance the overall player experience.
• Marketing communications: Sending you personalised promotional offers, bonus notifications, and platform updates where you have provided explicit consent to receive such communications. You may withdraw this consent at any time.

6 Legal Basis for Processing

hoki62 processes your personal data under the following legal bases, depending on the purpose:

• Contractual necessity: Processing required to fulfil the contract between you and hoki62 — including account creation, bet settlement, deposit and withdrawal processing, and KYC verification — is performed on the basis that it is necessary for the performance of our agreement with you.
• Legal obligation: Processing required to comply with AML, CTF, and other applicable regulatory obligations is performed on the basis of legal compliance.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and anonymised analytics is performed on the basis of hoki62's legitimate interests, provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for direct marketing communications is performed solely on the basis of your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7 Data Sharing & Disclosure

hoki62 does not sell, rent, or trade your personal data to third parties for their own commercial or marketing purposes. We share personal data only in the following limited circumstances:

• Payment processors: Your financial data is shared with the relevant bank or e-wallet provider (BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, or LinkAja) solely to the extent necessary to process your deposit or withdrawal transaction.
• KYC and identity verification providers: Your identity documents and personal details may be shared with third-party KYC service providers to perform identity and age verification on hoki62's behalf. These providers are contractually bound to process data only for the specified verification purpose.
• Game studios and software providers: Technical identifiers (such as a pseudonymous player ID) are shared with game studios such as Pragmatic Play, Evolution Gaming, Spribe, and Pocket Games Soft for the purpose of game session management and RNG certification. No personally identifiable information is shared with game studios beyond what is strictly necessary for game delivery.
• Fraud prevention services: Risk signals and device data may be shared with specialist fraud prevention partners to identify and block fraudulent activity across the platform.
• Legal and regulatory authorities: hoki62 will disclose personal data to law enforcement, regulatory bodies, or other competent authorities when required to do so by law, court order, or binding regulatory directive — including suspicious transaction reports mandated by applicable AML regulations.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of hoki62's business, your personal data may be transferred to the relevant successor entity, subject to equivalent data protection obligations.

All third-party data processors engaged by hoki62 are bound by formal data processing agreements that require them to process personal data only on hoki62's documented instructions and to implement appropriate technical and organisational security measures.

8 Data Retention

hoki62 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your active account plus a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of each transaction, in line with standard financial record-keeping obligations.
• KYC documentation: Identity documents submitted for verification are retained for a minimum of five (5) years following account closure or the date of the last transaction, whichever is later.
• Customer support communications: Retained for three (3) years from the date of the relevant support interaction, for quality assurance and dispute resolution purposes.
• Technical and behavioural data: Aggregated and anonymised after twelve (12) months for analytics purposes. Raw session logs are retained for up to ninety (90) days for security and fraud investigation purposes.
• Marketing consent records: Retained for the duration of your consent and for three (3) years following withdrawal of consent, as evidence of your consent and its withdrawal.

When personal data is no longer required for its original purpose and no legal retention obligation applies, hoki62 will securely delete or irreversibly anonymise that data.

9 Security Measures

hoki62 implements a layered approach to data security, combining technical controls, organisational policies, and ongoing staff training to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Key security measures include:

• TLS/SSL encryption: All data transmitted between your device and the hoki62 platform is encrypted using industry-standard Transport Layer Security (TLS) protocols.
• Encryption at rest: Sensitive personal data — including identity documents and financial details — is encrypted when stored on hoki62 servers.
• Access controls: Access to personal data is restricted to authorised hoki62 personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Multi-factor authentication: Internal systems that store or process personal data are protected by multi-factor authentication requirements for all staff access.
• Penetration testing and vulnerability management: hoki62 conducts regular security assessments, including penetration testing by qualified third-party specialists, to identify and remediate potential vulnerabilities.
• Incident response: hoki62 maintains a documented data breach response procedure. In the event of a security incident involving your personal data, we will notify you and the relevant authorities within the timeframes required by applicable law.

While hoki62 takes every reasonable precaution to protect your personal data, no digital platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying hoki62 immediately if you suspect unauthorised access to your account.

10 Cookies & Tracking Technologies

hoki62 uses cookies and similar tracking technologies to operate the platform effectively, remember your preferences, maintain your login session, and understand how players interact with the site. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the platform to function. These include session management cookies that keep you logged in during your visit. These cookies cannot be disabled without impairing platform functionality.
• Functional cookies: Remember your preferences such as language settings and display options, so you do not need to re-enter them on each visit.
• Analytics cookies: Collect anonymised data about how players navigate the hoki62 platform, which pages are most visited, and where errors occur. This data is used solely to improve the platform experience.
• Security cookies: Used by hoki62's fraud prevention systems to detect unusual session behaviour, identify bot activity, and protect accounts against credential stuffing attacks.

hoki62 does not use third-party advertising or behavioural targeting cookies. No cookie data is shared with advertising networks or data brokers.

You may manage or disable non-essential cookies through your browser settings at any time. Note that disabling certain cookies may limit the functionality of some areas of the hoki62 platform.

11 Your Rights Over Your Personal Data

As a hoki62 player, you have the following rights in relation to your personal data. To exercise any of these rights, please contact us using the details in the Contact section of this policy.

hoki62 will respond to all verified data rights requests within 30 calendar days. In cases of complexity or high volume, this period may be extended by a further 30 days with prior notice to you. Requests are free of charge unless manifestly unfounded or excessive.

12 Minors

The hoki62 platform is strictly intended for individuals who are at least 21 years of age. hoki62 does not knowingly collect personal data from individuals under 21. If we become aware that personal data has been collected from an individual under the age of 21, we will immediately suspend the relevant account, forfeit any associated balances, and securely delete the personal data collected, subject to any legal retention obligations that may apply.

If you believe that a minor has accessed hoki62 or that their personal data has been collected, please contact us immediately at [email protected] so that we may take prompt corrective action.

13 Changes to This Privacy Policy

hoki62 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or platform features. The "Last Updated" date at the top of this policy reflects the date of the most recent revision.

Where changes are material — for example, where we introduce a new purpose of processing or a new category of data sharing — hoki62 will provide advance notice via the platform or by email to your registered address before the changes take effect. Your continued use of the hoki62 platform following the effective date of any revised Privacy Policy constitutes your acknowledgement of the updated terms.

We encourage you to review this Privacy Policy periodically to stay informed about how hoki62 protects your personal data.

14 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by hoki62, please contact our dedicated privacy support team through the following channel:

• Email: [email protected]
• Live Chat: Available 24/7 directly through the hoki62 platform interface
• Response Time: hoki62 targets a response to all privacy-related enquiries within 30 calendar days of receipt

For data rights requests specifically (access, rectification, erasure, portability, objection), please include your full registered name, account username, and a description of your request in your message to help us process it efficiently. hoki62 may need to verify your identity before acting on a data rights request in order to protect against unauthorised access to another individual's personal data.