Privacy Policy — zxy33

1 Definitions

• "Personal Data" — Any information that identifies or could reasonably be used to identify a natural person, directly or indirectly. This includes name, date of birth, national identity number, contact details, financial data, IP address, and device identifiers.
• "Processing" — Any operation performed on Personal Data, including collection, recording, storage, alteration, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" — The entity that determines the purposes and means of processing Personal Data. For the purposes of this Policy, the Data Controller is zxy33, operated at https://zxy33.net.
• "Data Processor" — A third party that processes Personal Data on behalf of and under the instructions of zxy33, such as a KYC verification provider or payment gateway.
• "KYC Data" — Identity verification documentation, including a copy of the Player's Indonesian National Identity Card (KTP), proof of address, and any supplementary documentation requested during the account verification process.
• "Consent" — A freely given, specific, informed, and unambiguous indication of the Player's agreement to the processing of their Personal Data for one or more specified purposes.
• "Services" — All gaming, sportsbook, promotional, and customer-support services made available via the zxy33 platform.

2 Scope & Data Controller

This Policy applies to all Personal Data collected by zxy33 in connection with the operation of the Platform and the provision of the Services to Players located in Indonesia and any other jurisdiction from which access to the Platform is not legally prohibited.

The Data Controller responsible for your Personal Data is zxy33, accessible at https://zxy33.net. For all data-related enquiries, corrections, deletion requests, or complaints, please contact our dedicated privacy team at [email protected]. All privacy-related correspondence will be acknowledged within five (5) business days and resolved within thirty (30) calendar days wherever practicable.

3 Personal Data We Collect

3.1 Registration Data

When you create a zxy33 account, we collect the following information:

• Full legal name (as it appears on your Indonesian KTP)
• Date of birth (to verify the 21+ age requirement)
• Residential address in Indonesia (city, province, postcode)
• Email address and mobile phone number
• Chosen username and a securely hashed version of your password (we never store passwords in plain text)

3.2 Identity Verification (KYC) Data

Before your first withdrawal is processed, zxy33 requires:

• A clear digital copy of your Indonesian National Identity Card (KTP)
• Where additional verification is warranted: proof of residential address (e.g., a recent utility bill or bank statement issued in Indonesia), a selfie alongside your identity document, and/or source-of-funds documentation

3.3 Financial Data

To process deposits and withdrawals in IDR, zxy33 collects:

• Bank account details (account name, account number, bank name — e.g., BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, BSI)
• E-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja) where used as a payment method
• Transaction history: deposit amounts, withdrawal amounts, dates, and reference numbers

zxy33 does not store full card numbers or CVV codes. Card payment data is processed directly by our PCI-DSS-compliant payment gateway partners.

3.4 Technical & Usage Data

When you access the Platform, our servers automatically record:

• IP address and approximate geolocation (country and city level)
• Browser type, version, and language settings
• Operating system and device type
• Pages visited, time spent on each page, and navigation path through the Platform
• Session start and end timestamps (WIB — Western Indonesia Time, UTC+7)
• Referring URL (the page from which you arrived at zxy33)

3.5 Communications Data

When you contact zxy33 support — via live chat, WhatsApp, or email — we retain a record of the correspondence, including your name, contact details, and the content of the exchange. This record is used for quality assurance, dispute resolution, and fraud prevention.

3.6 Gaming Activity Data

zxy33 logs all gaming and betting activity on the Platform, including bets placed, games played, wager amounts in IDR, outcomes, and bonus participation. This data is used for account management, responsible gaming monitoring, fraud detection, and regulatory compliance.

4 How We Use Your Personal Data

zxy33 uses the Personal Data we collect for the following purposes:

zxy33 does not use your Personal Data to make fully automated decisions that produce significant legal effects without human oversight. Where automated tools are used for fraud detection or responsible gaming monitoring, a human review is conducted before any account action is taken.

5 Legal Basis for Processing

zxy33 processes your Personal Data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between zxy33 and the Player — including account creation, payment processing, and delivering the gaming Services.
• Legal obligation: Processing required to comply with applicable law, including anti-money laundering obligations, age-verification requirements, and record-keeping mandates.
• Legitimate interests: Processing undertaken to protect the security and integrity of the Platform, detect and prevent fraud, and improve the overall player experience — provided such processing does not override your fundamental privacy rights.
• Consent: Where zxy33 processes data for optional purposes — such as sending promotional emails about bonuses, new games, or seasonal promotions — we will obtain your explicit consent prior to doing so. You may withdraw this consent at any time by contacting support or adjusting your account notification settings.

6 Data Sharing & Disclosure

zxy33 does not sell or rent your Personal Data to any third party. We share your data only in the following circumstances, and only to the minimum extent necessary:

6.1 Service Partners

• KYC and identity verification providers: To verify your identity and age in accordance with our legal obligations.
• Payment processors and banking partners: To process IDR deposits and withdrawals via BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, LinkAja, and card networks (Visa, Mastercard).
• Fraud prevention and risk management platforms: To detect suspicious activity, prevent money laundering, and protect the security of the Platform.
• Game software providers: Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, Pocket Games Soft, and other certified studios may receive anonymised session data necessary to deliver game content. These providers do not receive personally identifiable data beyond what is technically required.
• Customer support infrastructure providers: Live-chat and ticketing system vendors who process support communications on our behalf under strict data-processing agreements.

6.2 Legal Disclosures

zxy33 may disclose Personal Data to law-enforcement authorities, regulators, courts, or other governmental bodies where required to do so by law, court order, or where we reasonably believe disclosure is necessary to protect the rights, property, or safety of zxy33, its players, or the public.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of the assets of zxy33, Personal Data held by zxy33 may be transferred to the acquiring entity as part of that transaction. Players will be notified via the registered email address on file before such a transfer takes effect and will be given the opportunity to request deletion of their data if they do not wish to continue using the successor platform.

7 International Data Transfers

The zxy33 platform and its service partners operate infrastructure in multiple jurisdictions. Personal Data collected from Indonesian Players may be transferred to, stored, and processed in countries outside Indonesia. Where such transfers occur, zxy33 ensures that appropriate safeguards are in place — including contractual data-protection clauses between zxy33 and all Data Processors — to maintain a standard of protection equivalent to that required by applicable data-protection law.

By registering a zxy33 account and accepting this Policy, you consent to the transfer of your Personal Data to jurisdictions outside Indonesia on the terms described in this section.

8 Data Retention

zxy33 retains Personal Data for as long as is necessary to fulfil the purpose for which it was collected, or as required by law. The following retention periods apply as a baseline:

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be attributed to an identifiable individual.

9 Cookies & Tracking Technologies

zxy33 uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These cookies manage your login session, maintain your account state across pages, and protect against cross-site request forgery. These cookies cannot be disabled without breaking core Platform functionality.
• Analytical / Performance Cookies: Used to collect aggregated, anonymised data on how Players navigate the Platform — pages visited, time on page, error occurrences. This data is used solely to improve Platform performance and user experience. No individual Player is identified through analytical cookies.
• Functional Cookies: Store your preferences such as language settings, preferred game category, and session-length alert thresholds to personalise your experience on return visits.

zxy33 does not use advertising cookies, retargeting pixels, or third-party social-media tracking scripts. You may configure your browser to refuse or delete cookies at any time; however, disabling strictly necessary cookies will prevent you from logging in to your account.

10 Security Measures

zxy33 employs a multi-layered approach to data security, including the following technical and organisational measures:

• 256-bit SSL/TLS encryption on all data transmissions between the Player's device and zxy33 servers.
• Encrypted password storage using industry-standard one-way hashing algorithms. Passwords are never stored in recoverable plain text.
• Role-based access controls limiting internal access to Personal Data to staff members who require it to perform their job functions.
• Regular security audits and penetration testing conducted by independent third-party cybersecurity firms.
• Intrusion detection systems and real-time monitoring for anomalous account activity.
• Data segregation ensuring that financial data and KYC documentation are stored in isolated, access-controlled environments separate from general platform databases.

While zxy33 implements robust security measures, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in a high risk to Players' rights and freedoms, zxy33 will notify affected Players without undue delay and will take all reasonable steps to contain and remediate the breach.

11 Your Data Rights

Subject to applicable law and any overriding legal-retention obligations, you hold the following rights over your Personal Data held by zxy33:

• Right of Access: You may request a copy of the Personal Data that zxy33 holds about you, including the categories of data, the purposes for which it is processed, and any third parties with whom it has been shared.
• Right to Rectification: You may request correction of any inaccurate or incomplete Personal Data. Where the correction relates to KYC or financial data, supporting documentation may be required.
• Right to Erasure ("Right to Be Forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where processing is unlawful. Note that data subject to a mandatory legal-retention period (e.g., AML records) cannot be deleted before that period expires.
• Right to Restriction of Processing: You may request that zxy33 restrict the processing of your data — for example, while a rectification request is being assessed.
• Right to Data Portability: Where processing is based on consent or contractual necessity, 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 based on legitimate interests, including profiling for responsible-gaming monitoring. Where you object, zxy33 will assess whether the legitimate interest overrides your objection and will respond within thirty (30) days.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing that occurred prior to withdrawal.

To exercise any of the above rights, please submit a written request to [email protected]. Include your registered username and a clear description of the right you wish to exercise. zxy33 will acknowledge your request within five (5) business days and provide a substantive response within thirty (30) calendar days.

12 Children & Minors

The zxy33 platform is strictly restricted to individuals who are at least 21 years of age. zxy33 does not knowingly collect Personal Data from any person under the age of 21. If zxy33 becomes aware that a minor has registered an account or provided Personal Data, all data associated with that account will be permanently deleted and the account will be closed immediately without notice.

If you are a parent or guardian and believe that a minor in your household has registered a zxy33 account, please contact us immediately at [email protected] so that the account can be closed and all associated data erased without delay.

13 Third-Party Links

The zxy33 platform may contain links to third-party websites — for example, links to game providers' information pages or payment-method support portals. These links are provided for informational convenience only. zxy33 does not operate, control, or endorse any third-party website, and this Privacy Policy does not apply to any third-party site or service. We encourage you to review the privacy policies of any third-party site you visit before providing Personal Data to that site.

14 Amendments to This Policy

zxy33 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, Platform features, or data-processing practices. Where a material change is made, zxy33 will notify active Players via the email address registered on their account or via a prominent notice on the Platform homepage, at least fourteen (14) days before the amended Policy takes effect.

The "Last Updated" date at the top of this page will always reflect the date of the most recent revision. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not accept the amended Policy, please contact support to close your account before the effective date.

15 Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data, please contact the zxy33 privacy team through the following channels:

• Email: [email protected] — please include "Privacy Request" in the subject line.
• Live Chat: Available 24/7 via the chat interface accessible after logging in to your zxy33 account.
• Response Time: Acknowledgement within 5 business days; substantive response within 30 calendar days.
• Support Hours: 24 hours a day, 7 days a week (WIB — UTC+7), including all Indonesian public holidays.

If you are not satisfied with zxy33's response to a privacy complaint, you have the right to escalate the matter to the relevant data-protection supervisory authority in the jurisdiction applicable to you. Our 24/7 support team includes Indonesian-speaking agents who can assist you in your preferred language throughout the complaints process.