Privacy Policy — loby89

loby89 processes your Personal Data on the following legal bases:

• Contractual necessity: Much of the processing described in this Policy is necessary for loby89 to perform its obligations under the agreement formed with you when you register a loby89 Account, including account administration, payment processing, and customer support.
• Legitimate interests: loby89 processes certain Technical and Usage Data on the basis of its legitimate interests in maintaining platform security, preventing fraud, improving its services, and ensuring responsible gaming compliance — provided those interests are not overridden by your fundamental rights and freedoms.
• Legal obligation: loby89 is required by law and its international operating license to process certain data, including KYC identity verification records and transaction histories, for anti-money laundering and regulatory compliance purposes.
• Consent: Where loby89 relies on your consent as the legal basis for processing — for example, for sending marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing that took place before withdrawal.

loby89 does not sell, rent, or trade your Personal Data to third parties for their own commercial purposes. loby89 may share your Personal Data with the following categories of third parties strictly for the purposes described in this Policy:

• KYC and identity verification providers: Third-party providers engaged to verify your identity, age, and document authenticity as part of the loby89 account registration and verification process.
• Payment service providers: Indonesian banks (including BCA, BRI, BNI, Mandiri, CIMB Niaga, and BSI) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) as necessary to process your deposits and withdrawal requests.
• Game software providers: Third-party casino and sportsbook software providers (such as Pragmatic Play, Evolution Gaming, PG Soft, and Microgaming) may process technical session data in connection with the delivery of their games on the loby89 Platform.
• Fraud prevention and security providers: Specialist firms engaged to detect and prevent fraud, money laundering, unauthorized access, and other security threats on the loby89 Platform.
• Regulatory and law enforcement authorities: Where loby89 is required by applicable law, court order, or regulatory directive to disclose Personal Data, it will do so. loby89 will notify you of such disclosures where permitted by law.
• Business transfers: In the event of a merger, acquisition, or sale of all or a substantial part of the loby89 Operator's business assets, your Personal Data may be transferred to the acquiring entity as part of that transaction, subject to equivalent data protection commitments.

All third parties with whom loby89 shares Personal Data are required to implement appropriate technical and organizational security measures and to process your data only in accordance with loby89's instructions and applicable data protection law.

loby89 retains your Personal Data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulatory obligation. The following general retention periods apply:

Upon expiry of the applicable retention period, Personal Data will be securely deleted or anonymized so that it can no longer be associated with an identified individual.

loby89 implements a range of technical and organizational security measures to protect your Personal Data against unauthorized access, accidental loss, destruction, or disclosure:

• SSL/TLS Encryption: All data transmitted between your device and the loby89 Platform is encrypted using industry-standard SSL/TLS protocols, ensuring that your login credentials, payment details, and personal information cannot be intercepted in transit.
• Data encryption at rest: Sensitive Personal Data stored on loby89 servers — including identity documents and financial account details — is encrypted at rest using AES-256 or equivalent encryption standards.
• Access controls: Access to Personal Data within loby89's internal systems is restricted on a strict need-to-know basis. Staff members are granted only the level of access required to perform their specific role.
• Two-factor authentication (2FA): Players are encouraged to enable 2FA on their loby89 Account for an additional layer of protection against unauthorized login attempts.
• Penetration testing and audits: The loby89 Platform undergoes regular security assessments, including penetration testing, vulnerability scanning, and third-party security audits, to identify and remediate potential weaknesses.
• Data breach response: In the event of a data breach that poses a risk to your rights and freedoms, loby89 will notify affected Players and, where required, the relevant supervisory authority, within the timeframes prescribed by applicable law.

The loby89 Platform uses cookies and similar tracking technologies to enhance your browsing experience, maintain your session state, and analyze Platform usage. The following types of cookies may be in use:

• Strictly necessary cookies: These cookies are essential for the loby89 Platform to function correctly. They enable core features such as session authentication, load balancing, and security token management. You cannot opt out of strictly necessary cookies without affecting Platform functionality.
• Functional cookies: These cookies remember your preferences — such as language settings and display preferences — to provide a more personalized experience on the loby89 Platform.
• Analytics cookies: loby89 uses analytics tools to understand how Players navigate and interact with the Platform. Analytics data is aggregated and anonymized where possible, and is used solely to improve Platform performance and user experience.
• Security cookies: These cookies support loby89's fraud detection and anti-abuse systems by helping to identify unusual patterns of access or activity associated with a particular device or session.

You may control cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the loby89 Platform — for example, disabling session cookies will prevent you from staying logged in. loby89 does not use third-party advertising cookies or behavioral retargeting cookies.

Subject to applicable law and any overriding legal obligations, you hold the following rights in respect of your Personal Data processed by loby89:

• Right of access: You have the right to request a copy of the Personal Data that loby89 holds about you, together with information about how it is being processed.
• Right to rectification: If any Personal Data loby89 holds about you is inaccurate or incomplete, you have the right to request that it be corrected. You may update most profile information directly from within your loby89 Account settings.
• Right to erasure: 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 unlawfully processed. Note that certain data — particularly KYC and financial transaction records — must be retained for regulatory compliance purposes and cannot be erased on request.
• Right to restriction: You may request that loby89 restrict the processing of your Personal Data in certain circumstances, for example while a rectification request is being assessed.
• Right to data portability: Where processing is based on consent or 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.
• Right to object: You have the right to object to processing of your Personal Data where loby89 relies on legitimate interests as the legal basis, including for marketing purposes. loby89 will cease such processing unless it 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. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

To exercise any of the above rights, please contact the loby89 Data Protection team at [email protected]. loby89 will respond to verified requests within 30 days. In cases of complexity or volume, this period may be extended by a further 60 days, with notification provided within the initial 30-day window.

The loby89 Platform is strictly intended for adults aged 21 and above. loby89 does not knowingly collect Personal Data from individuals under the age of 21. Age verification checks are conducted as part of the account registration and KYC process to enforce this restriction.

If loby89 becomes aware that Personal Data has been collected from a person under the age of 21, all such data will be deleted immediately and the associated Account will be closed. Any winnings or balances accrued on the Account will be voided.

If you are a parent or guardian and believe that a minor in your care has registered a loby89 Account, please contact us immediately at [email protected] so that the Account can be investigated and closed without delay.

loby89 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or loby89's data processing practices. When material changes are made, the updated Policy will be published on this page with a revised "Last updated" date.

Where changes are significant — for example, where loby89 begins processing a new category of Personal Data or sharing data with a new class of third parties — loby89 will provide advance notice to Players via email or an on-platform notification before the changes take effect.

Your continued use of the loby89 Platform following the publication of an updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with any amendment, you should stop using the Platform and may close your Account in accordance with the Terms & Conditions.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data by loby89, please contact our Data Protection team through the following channels:

• Email: [email protected] — please include "Privacy Request" in the subject line for faster routing.
• Live Chat: Available 24/7 directly on the loby89 Platform. Our support team includes native Indonesian-speaking agents who can assist with privacy-related inquiries in both English and Indonesian.
• Response commitment: loby89 targets acknowledgment of all privacy-related inquiries within 72 hours (WIB business hours) and substantive responses within 30 calendar days.

If you are not satisfied with loby89's response to a privacy inquiry, you may have the right to lodge a complaint with the relevant data protection authority in the jurisdiction in which the loby89 Operator is licensed.