Privacy Policy

1. Definitions

Term	Meaning
"Personal Data"	Any information that identifies or could reasonably identify a living individual, directly or in combination with other data held by air123.
"Processing"	Any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, erasure, or destruction.
"Data Subject"	The identified or identifiable natural person to whom Personal Data relates — in the context of this Policy, primarily air123 Members and website visitors.
"Data Controller"	The entity that determines the purposes and means of processing Personal Data — for this Platform, air123 as described in Clause 2.
"Third-Party Processor"	A company or individual engaged by air123 to process Personal Data on air123's behalf and under air123's documented instructions.
"Cookies"	Small text files placed on your device by the air123 website to facilitate session management, analytics, and personalisation features.
"KYC"	Know Your Customer — the regulatory identity verification process that requires Members to submit government-issued identification and proof of address.

2. Data Controller

2.1 air123, operating the Platform at https://air123.cam, acts as the Data Controller for all Personal Data processed in connection with Member accounts, gameplay, transactions, and general website interactions.

2.2 air123 operates under an international gaming licence and processes Personal Data in accordance with applicable data protection laws and international best practices. Our designated Data Protection contact can be reached at the support email address listed in Clause 15 of this Policy.

2.3 Where air123 engages Third-Party Processors — such as payment gateways, KYC verification providers, or game studios — those parties act under binding contractual data processing agreements that restrict their use of Member data exclusively to the purposes defined by air123.

3. Data We Collect

3.1 air123 collects the minimum Personal Data necessary to provide a safe, compliant, and high-quality gaming service. The categories of data we collect include:

3.1 Identity & Contact Data

• Full legal name (as it appears on your national identity document / KTP)
• Date of birth
• Indonesian residential address
• Email address
• Mobile telephone number
• Nationality and country of residence

3.2 Financial & Payment Data

• Bank account details (account name, account number, bank name — e.g., BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata)
• E-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja)
• Transaction history — deposit amounts, withdrawal requests, dates, and reference numbers
• Source of funds declarations (where required for compliance purposes)

3.3 Identity Verification (KYC) Data

• Government-issued photo identification (KTP — Kartu Tanda Penduduk, passport, or SIM)
• Proof of address documents
• Selfie or liveness-check images submitted during verification

3.4 Gaming & Activity Data

• Betting history — stakes, selections, odds, outcomes, and winnings across sports, casino, togel (traditional numbers lottery), and all other Platform products
• Session duration and login timestamps
• Game preferences and product usage patterns
• Responsible Gaming Tool activations (deposit limits, self-exclusion periods, cool-off requests)

3.5 Technical & Device Data

• IP address and approximate geographic location
• Browser type and version
• Operating system and device type
• Referring URL and session navigation path
• Cookie identifiers and locally stored preferences

3.6 Communications Data

• Content of messages sent to air123 Support via live chat, email, or contact form
• Records of promotional offers accepted or declined
• Feedback and survey responses submitted voluntarily

4. How We Collect Data

4.1 air123 collects Personal Data through the following channels:

• Direct submission: Data you provide when registering an Account, completing KYC, making a deposit or withdrawal request, or contacting Support.
• Automated technical collection: Data gathered automatically when you visit or interact with the Platform, including via cookies, server logs, and session tracking technologies.
• Third-party sources: Identity verification data returned by KYC providers; fraud-risk signals from payment processors; publicly available sanctions and politically exposed persons (PEP) screening databases used for anti-money-laundering (AML) compliance.

5. Lawful Basis for Processing

5.1 air123 processes Personal Data only where a valid lawful basis exists. The following table sets out the primary lawful bases applicable to our processing activities:

Processing Purpose	Lawful Basis
Account registration and service delivery	Performance of contract with the Member
Identity verification (KYC) and AML screening	Legal obligation / compliance with gaming licence conditions
Processing deposits and withdrawals	Performance of contract; legal obligation
Fraud detection and platform security	Legitimate interests of air123 and its Members
Responsible Gaming monitoring and intervention	Legal obligation; legitimate interests; Member protection
Sending transactional communications (account alerts)	Performance of contract
Sending promotional communications and bonus offers	Consent (opt-in at registration or subsequently)
Analytics and platform improvement	Legitimate interests (subject to cookie consent)

6. Use of Personal Data

6.1 air123 uses the Personal Data we collect for the following purposes:

• Creating and managing your Member Account, including authentication and access control.
• Verifying your identity and age (21+) in compliance with our gaming licence obligations.
• Processing deposits and withdrawals via your nominated Indonesian bank account or e-wallet.
• Settling bets, calculating winnings, and crediting Balances accurately.
• Detecting and preventing fraud, money laundering, match-fixing, and other prohibited activities.
• Operating Responsible Gaming Tools including deposit limit enforcement, self-exclusion, and reality-check notifications.
• Responding to Support enquiries and resolving disputes.
• Sending you important account-related communications (security alerts, terms updates, withdrawal confirmations).
• Sending you promotional offers and personalised bonus recommendations, where you have consented to receive such communications.
• Complying with legal obligations including tax reporting, AML screening, and regulatory audits.
• Improving Platform features, game selection, and user experience through aggregate analytics.

6.2 air123 will not use your Personal Data for any purpose that is incompatible with those listed above without first notifying you and, where required by applicable law, obtaining your explicit consent.

7. Data Sharing

7.1 air123 does not sell, rent, or trade your Personal Data to any third party for their own marketing or commercial purposes. We share data only in the following limited and controlled circumstances:

• Payment Processors: BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata, OVO, DANA, GoPay, ShopeePay, and LinkAja receive the minimum transactional data required to process your deposits and withdrawals.
• KYC & Identity Verification Providers: Our contracted KYC partner receives identity documents and biometric data solely for the purpose of verifying Member eligibility under our licensing obligations.
• Game Studios & Content Providers: Providers such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Pocket Games Soft may receive anonymised or pseudonymised session identifiers to facilitate gameplay and resolve technical disputes. No directly identifiable personal data is shared.
• Fraud & AML Screening Services: We may share transactional and identity data with licensed fraud-detection and sanctions-screening services to meet our AML compliance obligations.
• Law Enforcement & Regulatory Authorities: We will disclose Personal Data to government agencies, law enforcement bodies, or our licensing regulator where required to do so by law, court order, or binding regulatory instruction.
• Business Successors: In the event of a merger, acquisition, or sale of the Platform, Member data may be transferred to the successor entity, subject to the same data protection obligations as this Policy.

7.2 All Third-Party Processors engaged by air123 are bound by written data processing agreements that prohibit secondary use of Member data, require appropriate technical and organisational security measures, and mandate compliance with applicable data protection standards.

8. Cookies & Tracking Technologies

8.1 The air123 Platform uses cookies and similar tracking technologies to deliver a functional, personalised, and secure browsing experience. The principal cookie categories we deploy are:

Cookie Type	Purpose	Consent Required
Strictly Necessary	Session management, authentication, security tokens. Essential for Platform operation.	No
Functional	Remembering language preferences, game lobby settings, and display preferences.	No (legitimate interest)
Analytics	Aggregated, anonymised data on page views, navigation paths, and feature usage — used to improve the Platform.	Yes
Marketing	Tracking promotional campaign effectiveness and personalising bonus offers where consent has been given.	Yes

8.2 You may manage your cookie preferences at any time through your browser settings. Disabling strictly necessary cookies will impair the functionality of the Platform and may prevent you from logging in or completing transactions.

8.3 air123 does not use cookies to track your activity on third-party websites outside of the air123 Platform.

9. Data Retention

9.1 air123 retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by law. Our general retention schedule is as follows:

• Account and identity data: Retained for the duration of the active Account relationship plus a minimum of five (5) years following Account closure, to meet gaming licence audit and AML record-keeping obligations.
• Transaction and financial data : Retained for a minimum of five (5) years from the date of each transaction, consistent with financial record-keeping requirements.
• KYC documentation: Retained for five (5) years after Account closure or the last transaction date, whichever is later.
• Support communications: Retained for three (3) years from the date of the interaction, unless the communication relates to an unresolved dispute, in which case it is retained until the dispute is fully resolved.
• Analytics and technical data: Aggregated and anonymised after thirteen (13) months from collection; raw session logs are purged after ninety (90) days.
• Marketing consent records: Retained for the duration of the Member's active Account plus three (3) years to demonstrate compliance with consent obligations.

9.2 Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised. Where legal proceedings or regulatory investigations are ongoing at the expiry of the standard retention period, relevant data is preserved until those proceedings conclude.

10. Data Security

10.1 air123 implements a comprehensive set of technical and organisational security measures designed to protect Personal Data against unauthorised access, accidental loss, destruction, or disclosure:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the air123 Platform is encrypted in transit using industry-standard TLS 1.2 or higher.
• Encryption at Rest: Sensitive data fields — including payment account details and KYC documents — are encrypted at rest in our databases using AES-256.
• Access Controls: Internal access to Member data is restricted on a strict need-to-know basis. All staff with data access undergo regular security training and are bound by confidentiality obligations.
• Two-Factor Authentication: Administrative access to systems holding Member data requires multi-factor authentication.
• Regular Security Audits: The Platform undergoes periodic independent security assessments, penetration testing, and vulnerability scanning.
• Incident Response: air123 maintains a documented data breach response procedure. In the event of a breach likely to result in a risk to Members, affected individuals will be notified without undue delay.

10.2 While air123 employs all reasonable security measures, no online platform can guarantee absolute security. Members are responsible for maintaining the confidentiality of their own Account credentials and for notifying Support immediately upon suspecting any unauthorised Account access.

11. Your Rights as a Data Subject

11.1 Subject to applicable law and certain legitimate limitations, you hold the following rights in relation to your Personal Data held by air123:

Right	What It Means
Right of Access	You may request a copy of all Personal Data air123 holds about you, along with information about how it is being used.
Right to Rectification	You may request correction of any inaccurate or incomplete Personal Data held about you.
Right to Erasure	You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to overriding legal retention obligations.
Right to Restrict Processing	You may request that air123 restrict processing of your data in certain circumstances, such as while you contest its accuracy.
Right to Data Portability	Where processing is based on consent or contract, you may request that we provide your data in a structured, machine-readable format.
Right to Object	You may object to processing based on legitimate interests, including direct marketing. We will cease such processing unless we can demonstrate compelling grounds that override your interests.
Right to Withdraw Consent	Where processing is based on your consent (e.g., marketing emails), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

11.2 To exercise any of the above rights, please contact our Support team using the details in Clause 15. We will respond to all verified requests within thirty (30) calendar days. We may ask you to verify your identity before processing a rights request to prevent unauthorised disclosure.

11.3 Certain rights may be subject to limitations where fulfilling a request would conflict with our legal obligations — for example, KYC and AML record-keeping requirements that mandate retention of identity data for a prescribed period.

12. Minors

12.1 The air123 Platform is strictly intended for adults aged 21 years and over. We do not knowingly collect Personal Data from any individual under the age of 21.

12.2 If air123 discovers or is notified that Personal Data has been collected from an individual under 21, we will immediately close the associated Account, delete the relevant data to the extent permitted by law, and return any deposited funds through the relevant payment channel.

12.3 Parents and guardians who believe a minor may have created an Account on air123 are encouraged to contact Support immediately using the details in Clause 15 so the matter can be investigated and resolved promptly.

13. International Data Transfers

13.1 As an internationally operated Platform, air123 may transfer Personal Data to servers and service providers located outside of Indonesia. Where such transfers occur, air123 ensures that appropriate safeguards are in place to maintain the same standard of data protection that applies within Indonesia, including:

• Contractual clauses with processors that meet internationally recognised data protection standards.
• Transfers only to jurisdictions assessed as providing an adequate level of protection for personal data.
• Encryption of data in transit and at rest, as described in Clause 10.

13.2 By using the air123 Platform, you acknowledge and consent to the transfer of your Personal Data to our servers and processors as described in this clause, with the understanding that air123 maintains contractual and technical safeguards throughout.

14. Policy Amendments

14.1 air123 reserves the right to update or amend this Privacy Policy at any time. Material changes — those that significantly affect how we process your data or the rights available to you — will be communicated via a prominent notice on the Platform and, where appropriate, by email to the address registered on your Account.

14.2 The effective date of the most recent revision is displayed at the top of this page. We encourage Members to review this Policy periodically. Continued use of the Platform following the publication of an updated Policy constitutes acceptance of the revised terms.

14.3 If you do not agree with any amendment to this Policy, you should cease using the Platform and may request Account closure as described in the Terms & Conditions.

15. Contact & Complaints

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

15.2 Please include "Privacy Request" in the subject line of your email and provide sufficient detail to allow us to identify your Account and understand the nature of your request. We may request proof of identity before processing any data subject rights request.

15.3 If you are not satisfied with air123's response to a privacy concern, you have the right to escalate the matter to the relevant data protection authority or gaming regulator with jurisdiction over the Platform. air123 will cooperate fully with any such regulatory enquiry.

15.4 For matters relating to Responsible Gaming and self-exclusion, please visit our dedicated Responsible Gaming page. For the full scope of your contractual rights and obligations, please refer to the Terms & Conditions.