Privacy Policy

Overview

hoki65 is an internationally operated online betting and gaming platform serving English-preference players across Indonesia. As the data controller for personal information collected through the hoki65.cam Platform, we are committed to processing your data lawfully, transparently, and securely.

This Privacy Policy is written in plain English and structured to give you a clear, complete understanding of our data practices. It should be read alongside our Terms & Conditions, which govern the overall relationship between you and hoki65. Where a term used in this Policy is defined in the Terms & Conditions, that definition applies here as well.

We do not sell, rent, or trade your personal data to third parties for their own marketing purposes. Your information is used strictly to operate the Platform, comply with our legal and regulatory obligations, protect against fraud, and — where you have explicitly consented — to send you promotional communications about hoki65 products and offers.

Data We Collect

hoki65 collects personal data through several channels: directly from you during account registration and KYC verification, automatically through your use of the Platform, and occasionally from third-party service providers (such as payment processors and identity verification bureaus). The categories of data we collect include:

How We Use Your Data

hoki65 processes your personal data only for specific, clearly defined purposes. The table below maps each processing activity to its purpose and legal basis (detailed further in Section 4):

• Account Management: Creating and maintaining your member account, verifying your identity at registration and during KYC, managing your login credentials, and communicating account-status notifications.
• Transaction Processing: Processing deposits via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, LinkAja, and other supported channels; processing withdrawal requests to your nominated bank account or e-wallet; maintaining an accurate ledger of your account balance in IDR.
• Regulatory Compliance & AML: Fulfilling our anti-money-laundering (AML) and know-your-customer (KYC) obligations, screening transactions against sanctions lists, and retaining records as required by our international regulatory license.
• Platform Security & Fraud Prevention: Detecting and preventing fraudulent accounts, bonus abuse, multi-accounting, unauthorized access attempts, and other forms of Platform misuse. Technical data (IP address, device fingerprint) is integral to this function.
• Customer Support: Resolving queries, disputes, and technical issues raised through Live Chat, WhatsApp, or email. Support interaction records are retained to maintain conversation continuity and quality assurance.
• Responsible Gaming: Monitoring wagering patterns that may indicate problematic gambling behavior; administering deposit limits, cool-off periods, and self-exclusion requests; and facilitating referrals to external support resources where appropriate.
• Product Improvement: Analyzing aggregated, anonymized usage data to improve Platform design, game selection, payment flows, and customer experience. No individual user is identifiable in these analyses.
• Marketing Communications (Consent-Based Only): Sending promotional emails, WhatsApp messages, or in-Platform notifications about bonuses, new games, seasonal promotions (e.g., Idul Fitri, Nyepi, Indonesian Independence Day specials), and other hoki65 offers — but only where you have explicitly opted in to receive such communications.

Legal Basis for Processing

hoki65 processes your personal data on one or more of the following recognized legal grounds:

• Contractual Necessity: Processing that is required to perform the contract between you and hoki65 — i.e., to operate your account, process wagers, and handle deposits and withdrawals. Without this processing, we cannot provide the service.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including AML/KYC requirements imposed by our international operating license and financial regulations governing payments to and from Indonesia.
• Legitimate Interests: Processing that is necessary for hoki65's legitimate business interests — such as fraud detection, Platform security, product analytics, and responsible gaming monitoring — provided those interests are not overridden by your rights and interests.
• Consent: Processing for marketing communications, non-essential cookies, and any other purpose for which we have specifically asked for and received your explicit opt-in. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Data Sharing & Disclosure

hoki65 does not sell your personal data. We share your data only in the limited circumstances described below, and only to the extent necessary for the specified purpose:

• Payment Processors: Your financial data (bank account details, transaction amounts) is shared with our licensed payment processing partners to execute deposits and withdrawals. These partners are contractually bound to process your data only for payment execution purposes.
• Identity Verification Providers: KYC documents (ID photographs, selfies, address proofs) may be processed by a third-party identity verification bureau on our behalf to confirm identity and age. These providers operate under strict data processing agreements.
• Game Studio Providers: When you play games powered by third-party studios (such as Pragmatic Play, Evolution Gaming, Spribe, or Pocket Games Soft), your session data (user ID, bet amounts, game outcomes) is transmitted to the studio's servers to deliver the game. Game studios do not receive your full personal profile.
• Regulatory and Law Enforcement Authorities: Where required by law, court order, or the terms of our operating license, hoki65 may disclose personal data to competent authorities. We will notify you of any such disclosure to the extent legally permissible.
• Fraud Prevention Networks: In cases of suspected fraud or multi-accounting, anonymized or pseudonymized risk signals may be shared with industry fraud-prevention networks to protect the broader online gaming ecosystem.
• Corporate Transactions: In the event of a merger, acquisition, or sale of all or part of hoki65's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. You will be notified of any such change in advance.

Data Retention

hoki65 retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law and our regulatory obligations. The following retention periods apply:

• Active Account Data: Retained for the full duration of your account's active status, plus a minimum of 5 years following account closure. This covers identity data, contact data, financial data, and wagering history.
• KYC Documents: Identity verification documents (KTP photographs, selfies, address proofs) are retained for a minimum of 5 years following account closure to satisfy AML record-keeping requirements under our international operating license.
• Transaction Records: All deposit and withdrawal records, including amounts in IDR and payment method details, are retained for a minimum of 5 years following the date of each transaction.
• Support Communications: Live chat transcripts, WhatsApp records, and email correspondence are retained for 2 years from the date of the interaction, unless the communication relates to an open dispute or regulatory inquiry, in which case it is retained until the matter is fully resolved.
• Marketing Preferences: Records of your consent to — or opt-out from — marketing communications are retained for the duration of your account plus 3 years, to demonstrate compliance with consent obligations.
• Technical / Log Data: Server logs, IP address records, and device fingerprint data used for fraud detection and security purposes are retained for 12 months from the date of collection, after which they are automatically purged or anonymized.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be associated with any identifiable individual. If you request earlier deletion of your data (see Section 9 — Your Rights), we will assess the request against our legal retention obligations and inform you of the outcome within 30 days.

Data Security

hoki65 employs a layered security architecture to protect your personal and financial data against unauthorized access, disclosure, alteration, or destruction. Our key technical and organizational measures include:

• TLS 1.3 Encryption in Transit: All data transmitted between your browser or mobile device and hoki65 servers is encrypted using Transport Layer Security (TLS) 1.3 — the current industry-leading standard. Our SSL certificate is maintained and renewed continuously.
• Encryption at Rest: Sensitive personal data stored in our databases — including KYC documents, financial account details, and identity records — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data within hoki65's internal systems is governed by role-based access control (RBAC). Only staff members with a demonstrable operational need are granted access to personal data, and all access events are logged and auditable.
• Payment Data Isolation: hoki65 does not store full bank account numbers or e-wallet credentials on its own servers. Payment data is tokenized and handled directly by our PCI-DSS-compliant payment processing partners. The tokens stored by hoki65 cannot be reversed to retrieve the original payment credentials.
• Penetration Testing: The Platform undergoes periodic third-party penetration testing and vulnerability assessments to proactively identify and remediate security weaknesses.
• Staff Training: All hoki65 staff with access to personal data receive mandatory data protection training at onboarding and on an annual basis thereafter.
• Incident Response: hoki65 maintains a documented data breach response procedure. In the event of a security incident that poses a material risk to your personal data, we will notify affected Members within 72 hours of becoming aware of the breach, via email or in-Platform notification.

Cookies & Tracking

hoki65 uses cookies and similar tracking technologies to operate the Platform effectively, maintain your session, and analyze usage patterns. The following categories of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They manage your login session, maintain your account preferences, and ensure secure page navigation. These cookies cannot be disabled without impairing your ability to use the Platform.
• Functional Cookies: These cookies remember your settings and preferences — such as your preferred language (English), display resolution, and game lobby filters — to deliver a more personalized experience on return visits.
• Analytics Cookies: Aggregated, anonymized data about how Members navigate the Platform helps us improve page layout, game discoverability, and payment flows. Analytics data does not identify individual users and is used solely for internal product improvement.
• Fraud Detection Cookies: Device fingerprinting tokens and session-behavior signals are used by our fraud prevention systems to detect multi-accounting, bot activity, and other Platform abuse. These are classified as strictly necessary for Platform security.

hoki65 does not use third-party behavioral advertising cookies or permit ad networks to place tracking pixels on the Platform. Your browsing activity on hoki65.cam is not shared with advertising platforms for retargeting purposes.

You may manage non-essential cookies through your browser settings at any time. Disabling strictly necessary cookies may prevent certain features of the Platform from functioning correctly. For more information on managing cookies in popular browsers, refer to the support documentation provided by your browser vendor.

Your Rights

As a Member of hoki65, you hold specific rights with respect to the personal data we hold about you. These rights are detailed below. To exercise any of them, contact our Data Protection Officer using the details in Section 13.

All rights requests are handled at no charge. We aim to respond within 30 days of receipt; complex requests may require up to 60 days, in which case we will notify you of the extension. To verify your identity before processing a request, we may ask you to confirm your registered email address and provide a copy of a government-issued ID.

Minors & Age Verification

hoki65 is strictly an adults-only platform. You must be at least 21 years of age to register an account and use any feature of the Platform. We do not knowingly collect personal data from individuals under the age of 21.

Age verification is a mandatory component of our KYC process. All Members are required to submit a government-issued identity document (Indonesian KTP, SIM, or Passport) that clearly states their date of birth. Accounts where date-of-birth verification cannot be completed, or where the verified age is below 21, are immediately suspended and any deposited balance is returned to the originating payment method.

If you have reason to believe that a person under the age of 21 has registered an account on the Platform, please contact our support team immediately at [email protected]. We will investigate the matter promptly and take appropriate action, including permanent closure of the minor's account and secure deletion of their personal data.

International Data Transfers

hoki65 is operated by an internationally licensed entity with servers and infrastructure located outside Indonesia. When you use the Platform, your personal data will necessarily be transferred to and processed in jurisdictions outside Indonesia, including the jurisdiction in which hoki65 holds its operating license and the jurisdictions where our third-party service providers (payment processors, identity verification bureaus, game studios) maintain their infrastructure.

hoki65 ensures that all international transfers of personal data are subject to appropriate safeguards, which may include:

• Standard Contractual Clauses (SCCs) incorporated into Data Processing Agreements with third-party processors.
• Transfers to jurisdictions recognized as providing an adequate level of data protection under applicable international standards.
• Binding Corporate Rules where data is transferred within a corporate group subject to a group-wide data protection policy.

By registering an account on the Platform, you acknowledge that your personal data will be transferred internationally and consent to such transfers in accordance with this Privacy Policy.

Policy Amendments

hoki65 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When we make material changes, we will notify you through one or more of the following channels:

• A prominent notice displayed on the Platform upon your next login.
• An email notification sent to your registered email address.
• An in-Platform message in your account notifications inbox.

The "Last Updated" date at the top of this page will always reflect the date of the most recent revision. We encourage you to review this Policy periodically, particularly before making significant deposits or engaging with new Platform features. Your continued use of the Platform following publication of an amended Policy constitutes your acceptance of the revised terms.

Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or your personal data, please reach out through any of the following channels. Our Data Protection Officer (DPO) oversees all privacy-related matters and is available to assist you:

• Email: [email protected] — mark the subject line "Privacy Request" or "DPO Inquiry" for prioritized routing. We aim to respond to all formal privacy requests within 30 days (WIB business hours).
• Live Chat: Available 24/7 directly through the Platform. For initial privacy queries, our support agents can guide you to the correct escalation path. Typical first response: under 2 minutes during peak hours (08:00–24:00 WIB).
• WhatsApp: Our Indonesian-speaking support team is available around the clock via WhatsApp, including on public holidays such as Idul Fitri, Nyepi, and Indonesian Independence Day (17 August).

When submitting a formal data rights request (access, erasure, portability, etc.), please include your registered username, registered email address, and a brief description of your request to help us process it efficiently. Identity verification will be required before we action any request that involves disclosing or deleting personal data.