ink304 Privacy
Policy

ink304 ("we", "us", "our") operates the online betting and casino platform accessible at ink304.club (the "Platform"). As the data controller for all personal information collected through the Platform, ink304 is responsible for determining how and why your data is processed.

This Privacy Policy ("Policy") sets out the basis on which we collect, use, store, and disclose personal data obtained from Players, prospective Players, and visitors to the Platform. It applies to all services offered through ink304, including Sportsbook, In-Play Betting, Live Casino, Slots, Domino QQ, and togel (Indonesia's traditional numbers lottery) markets.

By registering an account, making a deposit, placing a bet, or otherwise using the Platform, you confirm that you have read, understood, and accepted the practices described in this Policy. If you do not agree with any part of this Policy, you should not use the Platform.

This Policy should be read in conjunction with the ink304 Terms & Conditions, which govern the overall contractual relationship between you and ink304.

In this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person — including name, email address, phone number, IP address, device identifier, and financial account details.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data. ink304 is the Data Controller for all data collected through the Platform.
• "Data Processor" means a third party that processes Personal Data on behalf of ink304 under a formal data processing agreement.
• "KYC Data" means identity and age verification documents submitted by a Player, including government-issued ID (KTP, passport, or SIM), proof of address, and bank account ownership documents.
• "Cookies" means small text files stored on a user's device by the Platform's web server to facilitate session management, analytics, and personalisation.
• "Player" means any registered account holder on the ink304 Platform.
• "Sensitive Data" means a subset of Personal Data that warrants heightened protection, including financial account details, KYC identity documents, and responsible gaming records.

ink304 collects the following categories of Personal Data from Players and Platform visitors:

ink304 collects Personal Data through the following methods:

1. Directly from you: When you complete the registration form, submit KYC documents, make a deposit or withdrawal request, contact our support team, or update your account preferences, you provide data directly to us.
2. Automatically through the Platform: When you access ink304.club, our servers automatically record Technical Data including your IP address, device identifiers, browser type, operating system, pages visited, and session timestamps. This data is collected via server logs and first-party cookies.
3. Through gameplay activity: Our gaming systems record all bet placements, game outcomes, session durations, and wager amounts as part of the operational record-keeping required for a licensed gaming platform.
4. From payment service providers: When you initiate a deposit or withdrawal via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, or LinkAja, our payment processors relay transaction confirmation data — including transaction reference numbers and account holder names — to ink304 for matching and reconciliation purposes.
5. From KYC verification partners: Where ink304 uses a third-party identity verification provider to authenticate submitted KYC documents, that provider may return verification status data, confidence scores, and document authenticity flags to ink304.
6. From fraud prevention and security tools: Our fraud monitoring systems may enrich your profile with risk-scoring data derived from device fingerprinting, behavioural analytics, and cross-platform verification signals.

ink304 processes your Personal Data for the following specific, legitimate purposes:

• Account creation and management: To register your account, verify your identity, maintain your account settings, and provide you with access to Platform services.
• KYC compliance: To verify that you are a natural person of at least 21 years of age residing in Indonesia, and to confirm that your payment methods are registered in your own name, as required by our anti-money-laundering obligations.
• Transaction processing: To credit deposits, process withdrawal requests, and maintain accurate financial records for all IDR transactions conducted on the Platform.
• Customer support: To respond to your enquiries, resolve disputes, process complaints, and maintain records of support interactions for quality assurance and audit purposes.
• Platform security and fraud prevention: To detect, investigate, and prevent unauthorised account access, collusion, bonus abuse, money laundering, and other prohibited activities as defined in the ink304 Terms & Conditions.
• Responsible gaming: To monitor gameplay patterns for indicators of problem gambling behaviour, enforce deposit limits and self-exclusion requests, and proactively contact Players who display signs of gambling-related harm.
• Legal and regulatory compliance: To fulfil obligations arising from applicable laws, including responding to lawful requests from Indonesian law enforcement, courts, or regulatory bodies.
• Promotional communications: Where you have opted in, to send you information about bonuses, promotions, new game releases, and seasonal offers relevant to your account activity. You may withdraw your marketing consent at any time via your account settings or by emailing [email protected].
• Platform improvement and analytics: To analyse aggregated, anonymised usage data to improve Platform performance, game selection, and user experience. Individual Players are not identified in Platform improvement analytics.

ink304 relies on the following legal bases for processing your Personal Data:

ink304 does not sell, rent, or trade your Personal Data to third parties for their own commercial purposes. We share data only in the following limited circumstances:

1. Payment service providers: We share the minimum necessary financial and identity data with our payment processing partners — including those operating the BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja integrations — to process your deposits and withdrawals. These providers act as Data Processors under formal data processing agreements with ink304.
2. KYC and identity verification providers: We share submitted KYC documents with our third-party identity verification partner solely for the purpose of document authenticity checks and age verification. Verified documents are not retained by the verification provider beyond the period required for the verification process.
3. Game content providers: Game studios — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft — receive session tokens and Player identifiers necessary to deliver game sessions and record outcomes. These providers do not receive your full name, contact details, or financial data.
4. Fraud prevention and security vendors: We share Technical Data and behavioural signals with fraud monitoring services to detect and prevent prohibited platform activity. These vendors process data solely on ink304's instruction.
5. Law enforcement and regulatory authorities: Where required by a lawful court order, regulatory directive, or law enforcement request, ink304 will disclose Personal Data to the relevant Indonesian authority. We will notify you of such a disclosure to the extent permitted by law.
6. Professional advisers: ink304's legal counsel, auditors, and compliance consultants may access Personal Data on a strictly need-to-know basis and are bound by professional confidentiality obligations.
7. Corporate transactions: In the event of a merger, acquisition, or sale of substantially all of ink304's assets, your Personal Data may be transferred to the acquiring entity, subject to equivalent privacy protections. You will be notified of any such transfer in advance.

ink304 retains Personal Data only for as long as is necessary for the purpose for which it was collected, or for as long as required by applicable legal and regulatory obligations. The following retention periods apply:

Upon the expiry of the applicable retention period, Personal Data is securely deleted or anonymised such that it can no longer be attributed to any individual. Where data is anonymised rather than deleted, the resulting anonymised dataset may be retained indefinitely for statistical and analytics purposes.

ink304 employs a comprehensive set of technical and organisational security measures to protect your Personal Data against unauthorised access, loss, destruction, or disclosure. These measures include:

• TLS/SSL encryption: All data transmitted between your device and the ink304 platform is encrypted using industry-standard TLS 1.2 or higher. The padlock icon in your browser confirms an active encrypted connection.
• Password hashing: Account passwords are never stored in plain text. ink304 uses a computationally intensive, salted hashing algorithm such that even internal staff cannot retrieve your password.
• Access controls: Personal Data is accessible only to ink304 personnel with a documented operational need. Access rights are reviewed quarterly and revoked immediately upon role change or employment termination.
• Database encryption at rest: Databases containing KYC documents and financial records are encrypted at the storage layer in addition to in-transit encryption.
• Penetration testing: The ink304 platform undergoes independent security penetration testing at least annually and after any major infrastructure change.
• Fraud monitoring: Real-time automated systems monitor for anomalous login behaviour, unusual transaction patterns, and device fingerprint mismatches — triggering alerts for human review where thresholds are breached.
• Data breach response: In the event of a confirmed personal data breach affecting Player accounts, ink304 will notify affected Players and, where legally required, the relevant authority, within 72 hours of confirming the breach. Notifications will be sent to the email address registered on your account.

ink304 uses first-party cookies and similar tracking technologies to operate the Platform, maintain your session, remember your preferences, and analyse Platform usage. We do not use third-party advertising cookies or cross-site tracking technologies.

You may control Functional and Analytics cookies via your browser settings. Disabling Strictly Necessary or Fraud Prevention cookies may impair the operation of your account or prevent login entirely. Clearing all cookies will log you out of your current session.

As a Platform user, you hold the following rights in relation to your Personal Data. To exercise any of these rights, submit a written request to [email protected] with the subject line "Data Rights Request" and verification of your account identity.

1. Right of Access: You may request a copy of all Personal Data ink304 holds about you, together with information on how that data is used and with whom it has been shared.
2. Right to Rectification: If any Personal Data ink304 holds about you is inaccurate or incomplete, you may request that it be corrected or updated. Minor corrections — such as updating a registered email address or phone number — can be made directly via your account settings.
3. Right to Erasure ("Right to be Forgotten"): You may request deletion of your Personal Data. This right is subject to ink304's legal data retention obligations — we cannot delete data that we are legally required to retain (such as KYC documents and financial transaction records within their mandatory retention periods).
4. Right to Restriction: You may request that ink304 restrict the processing of your Personal Data in certain circumstances — for example, where you contest the accuracy of the data while we verify it, or where you object to processing based on legitimate interests pending our assessment of your objection.
5. Right to Data Portability: Where processing is based on your consent or on contract performance, and is carried out by automated means, you may request a machine-readable export of the Personal Data you have provided to ink304 (e.g., registration data, gameplay history summary).
6. Right to Object: You may object at any time to processing of your Personal Data for direct marketing purposes. Upon receipt of such an objection, ink304 will cease all marketing communications immediately. You may also object to processing based on legitimate interests, subject to ink304 demonstrating compelling overriding grounds.
7. Right to Withdraw Consent: Where processing is based solely on your consent (e.g., marketing emails), you may withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

ink304 will respond to data rights requests within 30 calendar days of receipt. In complex cases, this period may be extended by a further 60 days, in which case we will notify you of the extension and the reason within the initial 30-day window.

The ink304 Platform is strictly intended for adults aged 21 years and above. ink304 does not knowingly collect Personal Data from individuals under the age of 21, and the Platform is designed to prevent minor access through mandatory KYC age verification.

Where ink304 discovers or is notified that an account has been registered by or on behalf of a person under 21 years of age, the following actions will be taken immediately:

• The account will be permanently closed and access revoked.
• Any deposit balance will be refunded to the source payment method where technically possible; no winnings will be paid out.
• All Personal Data associated with the minor's account will be deleted from active systems as quickly as our legal obligations permit. Certain records may be retained for a limited period for the purposes of investigation and legal compliance only.
• Where there is evidence of deliberate misrepresentation of age, the matter may be referred to the relevant Indonesian authority.

ink304 is an internationally operated platform. Some of the third-party service providers we engage — including certain game content studios, KYC verification partners, and fraud prevention vendors — are based outside Indonesia and may process your Personal Data in their own jurisdictions.

Where Personal Data is transferred outside Indonesia, ink304 ensures that appropriate safeguards are in place to protect that data to a standard at least equivalent to the protections provided under this Policy. Safeguards employed include:

• Contractual clauses in data processing agreements with all third-party processors that impose data protection obligations consistent with this Policy.
• Transfer only to processors operating in jurisdictions or under certification schemes that provide recognised adequate levels of data protection.
• Technical controls that limit the Personal Data transferred to the minimum necessary for the processor's specific function.

By using the ink304 Platform, you acknowledge that your Personal Data may be transferred to, stored in, and processed in countries other than Indonesia. ink304 takes all reasonable steps to ensure such transfers are conducted securely and in accordance with this Policy.

ink304 reserves the right to amend, update, or replace this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, platform functionality, or data processing practices. The "Last Updated" date at the top of this page will always reflect the effective date of the current version.

Where a proposed amendment is material — meaning it introduces a new processing purpose, a new category of data shared with third parties, or a reduction in any of your data rights — ink304 will provide at least 14 days' advance notice by posting a prominently labelled update notice on this page and, where practicable, by sending a notification to your registered email address.

Your continued use of the ink304 Platform after the effective date of any amendment constitutes your acceptance of the updated Policy. If you do not accept a material amendment, you must close your account before the amendment's effective date and cease using the Platform.

Minor amendments — including grammatical corrections, clarifications that do not alter substantive meaning, or updates to reflect changes in our third-party provider names — may be made without prior notice.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way ink304 handles your Personal Data, please contact our Data Protection team using the details below:

• Email: [email protected]
• Subject Line: "Privacy Policy Enquiry" or "Data Rights Request"
• Response Time: Within 3 business days for general enquiries; within 30 calendar days for formal data rights requests
• Operating Hours: Monday–Sunday, 09:00–21:00 WIB (UTC+7)

All formal data rights requests must be submitted in writing to the email address above. Requests made via live chat or telephone cannot be actioned as formal data rights requests due to the identity verification requirements associated with such requests.