Privacy Policy

Introduction

momo89 ("we", "us", "our") is committed to protecting the privacy and personal data of every individual who accesses or uses our Platform at https://momo89.cam. This Privacy Policy describes our data practices in full, including what personal information we collect, why we collect it, how we use and share it, how long we retain it, and what rights you hold over your own data.

This Policy applies to all registered members, visitors, and prospective users of the momo89 Platform, regardless of whether you are accessing from Jakarta, Surabaya, Bandung, Medan, Bali, or any other location. By creating an Account or continuing to use our Platform after being presented with this Policy, you acknowledge that you have read and understood its contents.

This Privacy Policy should be read alongside our Terms & Conditions, which govern the overall relationship between you and momo89. In the event of any conflict between this Policy and the Terms & Conditions on a matter of data privacy, this Privacy Policy prevails.

1. Definitions

For the purposes of this Privacy Policy, the following terms are defined as follows:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, date of birth, address, email address, phone number, KTP number, IP address, and financial account details.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, deletion, or any combination thereof.
• "Data Controller" means momo89, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of momo89 under a contractual agreement, including payment processors, KYC providers, and analytics vendors.
• "Platform" means the website at https://momo89.cam and all associated services, tools, and features.
• "Cookies" means small text files placed on your device by the Platform to facilitate session management, analytics, and personalization functions.
• "KYC" means Know Your Customer — the identity verification process using government-issued identification such as an Indonesian KTP (Kartu Tanda Penduduk).
• "Sensitive Data" means a subset of Personal Data warranting heightened protection, including government ID numbers, financial account details, and any data that could be used to identify a person's religious affiliation or other protected characteristic.

2. Data We Collect

momo89 collects Personal Data in several categories depending on the nature of your interaction with our Platform. The table below provides a structured overview of the categories of data we hold and their typical sources:

momo89 does not intentionally collect Sensitive Data beyond what is strictly necessary for identity verification and regulatory compliance. We do not collect data concerning racial or ethnic origin, religious beliefs, political opinions, health conditions, or sexual orientation.

3. How We Collect Data

3.1 Directly From You

The majority of your Personal Data is collected directly from you at the point you interact with our Platform. This includes data entered during registration, data submitted during KYC verification, payment details entered when making deposits or requesting withdrawals, and information shared when you contact our customer support team.

3.2 Automatically Through Technology

When you visit or use the momo89 Platform, certain technical data is collected automatically through server logs, cookies, pixel tags, and similar tracking technologies. This data includes your IP address, session duration, device characteristics, and behavioral data about how you navigate the Platform.

3.3 From Third Parties

momo89 may receive Personal Data about you from trusted third parties in specific circumstances:

• Payment processors (such as Indonesian banks BCA, BRI, BNI, Mandiri, and e-wallet operators OVO, DANA, GoPay, ShopeePay, LinkAja) may share transaction confirmation data
• KYC verification partners may return validation results against government identity databases
• Fraud prevention services may flag IP addresses or device fingerprints associated with known fraudulent activity
• Affiliate partners may pass referral tracking identifiers when you arrive at momo89 via an affiliated marketing channel

4. Purposes of Processing

momo89 processes your Personal Data only for specific, legitimate purposes. We do not use your data in ways that are incompatible with the purpose for which it was originally collected. Our primary processing purposes are:

• Account creation and management: To register your Account, verify your identity, manage your profile, and handle login authentication
• Service delivery: To process bets, settle winnings, manage deposits and withdrawals through BCA, BRI, BNI, Mandiri, and supported e-wallets, and to operate our casino and sports betting services
• KYC and regulatory compliance: To verify that you meet our minimum age requirement of 21 years and to comply with anti-money laundering (AML) and counter-terrorism financing (CTF) obligations
• Customer support: To respond to your inquiries, resolve disputes, and assist with account issues through live chat, email, and WhatsApp
• Platform security and fraud prevention: To detect and prevent unauthorized access, duplicate accounts, bonus abuse, and other fraudulent or prohibited activities
• Personalization and user experience: To remember your preferences, display relevant promotions, and tailor your Platform experience based on your activity history
• Marketing communications: To send you promotional offers, bonus notifications, and seasonal campaign information — only where you have provided explicit consent or where a legitimate interest applies
• Responsible gaming: To monitor betting patterns, enforce deposit limits and self-exclusion requests, and proactively identify users who may be exhibiting signs of problem gambling
• Legal and regulatory obligations: To maintain records required by applicable law, respond to lawful requests from regulatory authorities, and defend legal claims

5. Legal Basis for Processing

momo89 processes your Personal Data on one or more of the following lawful bases, depending on the specific purpose and context of each processing activity:

5.1 Contractual Necessity

Processing is necessary to perform the contract between you and momo89 — specifically, to operate your Account, process your bets, settle your winnings, and handle your deposits and withdrawals. Without this processing, we cannot deliver the core services you have signed up for.

5.2 Legal Obligation

Certain processing activities are required by law, including identity verification under AML regulations, record-keeping for financial transaction reporting, and cooperation with lawful requests from competent regulatory or law enforcement authorities.

5.3 Legitimate Interests

momo89 may process your data where it is necessary for our legitimate business interests, provided those interests are not overridden by your fundamental rights and freedoms. Legitimate interest purposes include fraud detection, network security, internal analytics, and improving Platform performance.

5.4 Consent

Where required — in particular for optional marketing communications and non-essential cookies — momo89 will seek your explicit, informed consent before processing your data. You may withdraw consent at any time without affecting the lawfulness of processing that occurred prior to withdrawal. To withdraw consent for marketing emails, use the unsubscribe link included in every promotional communication or contact our support team.

6. Data Sharing & Disclosure

momo89 does not sell, rent, or trade your Personal Data to third parties for their own marketing purposes. We share your data only in the following limited and controlled circumstances:

6.1 Service Providers and Data Processors

We engage carefully selected third-party service providers who process data on our behalf under strict contractual obligations. These include:

• Payment processors: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) receive the transaction data necessary to process your deposits and withdrawals
• KYC and identity verification partners: Receive your identity documents and personal details solely to perform verification checks
• IT infrastructure providers: Cloud hosting and security providers who store and protect Platform data
• Customer support platforms: Live chat and ticketing system providers who facilitate communication between you and our support team
• Analytics providers: Tools used to analyze anonymized usage patterns and improve Platform performance

6.2 Regulatory and Legal Disclosure

momo89 may disclose your Personal Data to government bodies, law enforcement agencies, or regulatory authorities when required to do so by applicable law, court order, or binding regulatory direction. We will, where legally permitted, notify you of such disclosure.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets involving momo89, your Personal Data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and of any material changes to this Privacy Policy that result from it.

7. Cookies & Tracking Technologies

momo89 uses cookies and similar tracking technologies to ensure the Platform functions correctly, to understand how users interact with our services, and to deliver a more personalized experience. The following categories of cookies are in use:

Strictly necessary cookies are placed without your consent as they are essential to Platform operation. All other cookie categories are activated only with your prior consent. You may manage your cookie preferences at any time through your browser settings. Note that disabling certain functional cookies may affect your experience on the Platform.

8. Data Retention

momo89 retains your Personal Data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulatory obligations. Our standard retention periods are as follows:

• Account and identity data: Retained for the lifetime of your Account plus a minimum of 5 years following Account closure, in accordance with AML record-keeping requirements
• Transaction and financial data: Retained for a minimum of 5 years from the date of each transaction, consistent with financial services regulatory standards
• KYC documents: Retained for a minimum of 5 years following Account closure or the completion of the most recent transaction, whichever is later
• Customer support communications: Retained for 2 years from the date of the final communication in each support interaction
• Technical and usage data: Retained for up to 24 months in identifiable form; may be retained in fully anonymized, aggregated form indefinitely
• Marketing consent records: Retained for the duration of the consent period plus 2 years as evidence of consent

When your data is no longer required for any legitimate retention purpose, momo89 will securely delete or permanently anonymize it using industry-standard data destruction methods.

9. Data Security

momo89 implements a comprehensive set of technical and organizational security measures to protect your Personal Data against unauthorized access, disclosure, alteration, and destruction. Our security infrastructure includes:

• SSL/TLS encryption: All data transmitted between your browser and our servers is encrypted using industry-standard SSL/TLS protocols (minimum TLS 1.2)
• Encryption at rest: Sensitive data fields — including financial account numbers, KTP numbers, and identity documents — are encrypted at the database level using AES-256 encryption
• Access controls: Personal Data is accessible only to authorized momo89 personnel who require it to perform their specific job functions, enforced through role-based access control (RBAC) systems
• Two-factor authentication: Administrative access to systems holding Personal Data requires multi-factor authentication
• Regular security audits: Our Platform and infrastructure undergo regular penetration testing and third-party security audits
• Incident response plan: momo89 maintains a documented data breach response procedure and will notify affected users and relevant authorities within 72 hours of becoming aware of a qualifying breach

10. Your Data Rights

As a user of the momo89 Platform, you hold the following rights with respect to your Personal Data. To exercise any of these rights, please contact our Data Privacy team using the details in Section 14:

10.1 Right of Access

You have the right to request a copy of all Personal Data we hold about you. We will respond to access requests within 30 days and provide your data in a structured, commonly used format.

10.2 Right to Rectification

You have the right to request correction of any inaccurate or incomplete Personal Data we hold about you. Some corrections — particularly to identity fields — may require re-submission of KYC documents.

10.3 Right to Erasure

You may request deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent, or where you object to processing on legitimate interest grounds. This right is subject to overriding legal retention obligations — for example, we cannot delete financial transaction records that are required by law to be retained for 5 years.

10.4 Right to Restriction

You may request that momo89 restrict processing of your Personal Data in certain circumstances, such as while a dispute about accuracy is being resolved or while an objection to legitimate interest processing is being assessed.

10.5 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 machine-readable format and to transmit it to another data controller.

10.6 Right to Object

You have the right to object to processing based on legitimate interests, including profiling, and to object to direct marketing communications at any time. Upon receipt of a valid objection, momo89 will cease the relevant processing unless compelling legitimate grounds can be demonstrated.

10.7 Rights Related to Automated Decision-Making

momo89 may use automated systems to assess fraud risk, verify account eligibility, or flag suspicious betting patterns. You have the right to request human review of any automated decision that significantly affects you, and to contest such decisions where you believe they are incorrect.

11. Minors & Age Restriction

The momo89 Platform is strictly intended for adults aged 21 years and over. We do not knowingly collect Personal Data from individuals under the age of 21. If you are under 21, you must not register an Account or use our Platform under any circumstances.

momo89 uses mandatory KYC verification to confirm the age of all registered members. Any Account found to belong to a person under 21 will be immediately suspended, all balance will be withheld pending investigation, and the matter may be referred to relevant authorities where required by law.

If you are a parent or guardian and believe that a minor in your care has registered an Account on momo89, please contact our support team immediately at [email protected]. We will investigate and close the Account, returning any deposited funds to the verified payment method and deleting all associated Personal Data within a reasonable timeframe.

12. International Data Transfers

As a globally operated platform serving Indonesian users, momo89 may transfer your Personal Data to servers, service providers, or partner organizations located outside Indonesia. Such transfers may include countries whose data protection frameworks differ from Indonesian law.

When transferring Personal Data internationally, momo89 ensures that appropriate safeguards are in place, including:

• Standard contractual clauses requiring the recipient to protect your data to a standard equivalent to this Policy
• Transfers only to recipients in jurisdictions deemed to provide an adequate level of data protection
• Binding corporate rules where data is transferred within a corporate group

By using the momo89 Platform, you acknowledge and consent to the international transfer of your Personal Data under the safeguards described above.

13. Policy Amendments

momo89 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered users via email and/or a prominent notice on the Platform at least 7 days before the changes take effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. We encourage you to review this page periodically to stay informed of how your data is being protected. The current version of this Policy is always available at https://momo89.cam/privacy-policy.

14. Contact & Data Inquiries

If you wish to exercise any of your data rights, have a question about this Privacy Policy, or wish to raise a concern about how momo89 handles your Personal Data, please contact our Data Privacy team through any of the following channels. All contact details are provided as plain text — they are not clickable links:

• Email (Data Privacy): [email protected] — please use the subject line "Data Privacy Request — [Your Username]"
• Live Chat: Available 24 hours a day, 7 days a week through your momo89 Account dashboard
• Response Time: We aim to acknowledge all data rights requests within 5 business days (WIB) and to resolve them within 30 calendar days

For general account support, bonus queries, or technical issues unrelated to data privacy, please visit our FAQ page for quick answers, or contact our general support team through live chat.

For concerns related to responsible gaming or self-exclusion, please visit our Responsible Gaming page where dedicated tools and guidance are available.