Privacy Policy

1 Introduction

demo88 ("we", "us", "our") operates the online gaming and sports betting Platform accessible at https://demo88.cam. As part of delivering our services to players across Indonesia and other eligible jurisdictions, we necessarily collect and process certain categories of personal data. We take this responsibility with the utmost seriousness.

This Privacy Policy is intended to provide you with a complete and transparent account of our data practices. It covers the categories of data we collect, the legal basis on which we process that data, the parties with whom we may share it, the security measures we employ to protect it, the retention periods that apply, and the rights you may exercise over your own information at any time.

This policy should be read in conjunction with our Terms & Conditions, which govern the overall contractual relationship between demo88 and registered players. In the event of any conflict between this Privacy Policy and the Terms & Conditions with respect to data handling, this Privacy Policy shall prevail.

2 Definitions

For the purposes of this Privacy Policy, the following terms carry the meanings set out below:

• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, contact details, financial account information, device identifiers, and behavioral data.
• "Processing" — any operation performed on personal data, including collection, recording, storage, adaptation, retrieval, use, disclosure, transmission, or deletion.
• "Data Controller" — demo88, the entity that determines the purposes and means of processing your personal data.
• "Data Processor" — any third party that processes personal data on behalf of demo88 under a written data processing agreement.
• "Platform" — the website at https://demo88.cam, including all subdomains, mobile interfaces, and associated software services.
• "Player" / "you" — any natural person who accesses, registers for, or uses any service available on the Platform.
• "KYC Data" — identity verification documentation collected for Know Your Customer compliance purposes, including government-issued ID, proof of address, and selfie photographs.
• "Sensitive Data" — a subset of personal data warranting heightened protection, including financial account credentials, identity document copies, and data revealing a player's health or vulnerability status (relevant to responsible gaming assessments).

3 Data We Collect

demo88 collects personal data across several categories, each serving a specific and documented operational purpose. The table below sets out these categories in detail.

4 How We Collect Data

4.1 Data You Provide Directly

The majority of personal data demo88 holds is provided directly by you during the course of your relationship with us. This includes information submitted at registration, data provided during KYC verification, payment details entered in the cashier section, and communications you initiate with our customer support team.

4.2 Data Collected Automatically

When you access the Platform, certain technical data is collected automatically through server logs, session tracking technologies, and browser-based scripts. This includes your IP address, device identifiers, browser configuration, and navigation behavior within the Platform. This data is used principally for security monitoring and to maintain the integrity of the gaming environment.

4.3 Data from Third Parties

In limited circumstances, demo88 may receive personal data about you from authorized third parties. These include identity verification service providers engaged to support KYC processes, payment processors confirming the status of deposit and withdrawal transactions, and fraud detection partners providing risk signals associated with your account activity. Any third-party data sharing is governed by binding data processing agreements.

5 Purposes of Processing

demo88 processes your personal data only for purposes that are lawful, specific, and proportionate. The following are the primary purposes for which we use the data we collect:

5.1 Account Management and Service Delivery

We process identity and contact data to create and maintain your player account, authenticate your login sessions, process your deposits and withdrawals through local Indonesian payment channels, and deliver the betting and gaming services you request. This processing is necessary for the performance of our contract with you.

5.2 Regulatory Compliance and AML

As an internationally licensed gaming operator, demo88 is obligated to comply with anti-money laundering (AML) regulations, counter-terrorism financing (CTF) requirements, and Know Your Customer (KYC) standards. We process identity documents and transaction data to fulfill these obligations. This processing is required by law and cannot be waived at the player's request.

5.3 Fraud Prevention and Security

Technical data, financial data, and account activity data are analyzed to detect and prevent fraudulent account use, multi-accounting, bonus abuse, and unauthorized access attempts. This is in demo88's legitimate interest and, where applicable, in the interest of protecting other players on the Platform.

5.4 Responsible Gaming Monitoring

We analyze wagering patterns, session frequency, deposit velocity, and self-reported player data to identify signs of problem gambling behavior. Where such indicators are identified, our responsible gaming team may make contact to offer support tools including deposit limits, cooling-off periods, and self-exclusion. This processing serves both a legal obligation and a legitimate interest in player welfare. Full details are available on our Responsible Gaming page.

5.5 Marketing and Personalization

Where you have provided explicit consent, we may use your account activity data and stated preferences to send you relevant promotional offers, bonus notifications, and personalized game recommendations. You may withdraw your marketing consent at any time by contacting support or adjusting your account notification preferences. Withdrawal of marketing consent does not affect the lawfulness of processing carried out before the withdrawal.

5.6 Customer Support

Communications data collected through live chat, email, and support tickets is used to resolve your queries, investigate complaints, and maintain records required for dispute resolution. Support communications may be reviewed for quality assurance and training purposes.

6 Legal Basis for Processing

demo88 relies on the following legal bases to process your personal data, consistent with internationally recognized data protection standards:

• Contractual Necessity: Processing required to fulfill our obligations under the Terms & Conditions — including account management, payment processing, and service delivery.
• Legal Obligation: Processing mandated by applicable laws and regulations, including AML/CTF compliance, KYC requirements, and record-keeping obligations imposed by our international gaming license.
• Legitimate Interests: Processing conducted in the legitimate interests of demo88 or third parties, including fraud prevention, platform security, responsible gaming monitoring, and business analytics — provided these interests are not overridden by your fundamental rights.
• Consent: Processing based on your freely given, specific, and informed consent — principally for direct marketing communications and optional personalization features. You may withdraw consent at any time without detriment to your account status.

7 Data Sharing and Disclosure

demo88 does not sell, rent, or trade your personal data to any third party for that party's own commercial purposes. We share personal data only in the specific circumstances described below, and always subject to appropriate safeguards.

7.1 Service Providers and Data Processors

We engage a limited number of trusted third-party service providers who process personal data on our behalf under binding data processing agreements. These include identity verification services, payment processors facilitating transactions through BCA, BRI, BNI, Mandiri, and e-wallet platforms, cloud infrastructure providers, cybersecurity partners, and customer support software vendors. All processors are contractually prohibited from using your data for any purpose other than delivering the specific service for which they have been engaged.

7.2 Game and Content Providers

Certain game studios and live casino providers — including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Pocket Games Soft — may receive limited technical session data necessary to operate their games within the Platform environment. This data does not include your full identity or financial account details.

7.3 Regulatory and Law Enforcement Authorities

demo88 will disclose personal data to competent regulatory bodies, law enforcement agencies, or judicial authorities where required to do so by law, court order, or in response to a lawful request. We will, where permitted by law, notify you of any such disclosure.

7.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of demo88's business assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any material change to how your data is processed as a result.

8 International Data Transfers

As an internationally operating platform, demo88 may process and store personal data on servers located outside of Indonesia. Where personal data is transferred to jurisdictions that do not provide an equivalent level of data protection to that available in Indonesia, we implement appropriate safeguards to ensure your data remains protected. These safeguards include standard contractual clauses, binding corporate rules where applicable, and vendor security assessments. By using the Platform, you acknowledge that your personal data may be processed in jurisdictions outside Indonesia in accordance with this policy.

9 Data Retention

demo88 retains personal data for no longer than is necessary to fulfill the purposes for which it was collected, subject to any legal retention obligations that require us to keep records for specified minimum periods. The following general retention guidelines apply:

• Account and Identity Data: Retained for the duration of the account's active status, plus a minimum of five (5) years following account closure, as required by AML and gaming license record-keeping obligations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction in accordance with applicable financial regulations.
• KYC Documentation: Retained for the duration of the account plus five (5) years post-closure. Documents may be retained longer where required by law or ongoing investigations.
• Support Communications: Retained for a period of two (2) years from the date of the most recent communication in a given case file, unless a live dispute extends this period.
• Marketing Preference Data: Retained until you withdraw consent or close your account, whichever occurs first.
• Technical and Log Data: Retained for up to twelve (12) months from the date of collection, unless retained longer for active security investigations.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymized in a manner that prevents reconstruction of individual identifiers.

10 Security Measures

demo88 implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. Our security framework includes:

• SSL/TLS Encryption: All data transmitted between your browser and the Platform is encrypted using industry-standard SSL/TLS protocols. Look for the padlock icon in your browser address bar when accessing demo88.
• Data Encryption at Rest: Sensitive personal data stored on our infrastructure, including KYC documents and financial records, is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data within demo88's systems is strictly limited on a need-to-know basis. Staff with data access are subject to background screening and mandatory data protection training.
• Two-Factor Authentication: Players are encouraged to enable two-factor authentication (2FA) on their accounts. Internal systems with access to player data require 2FA for all staff.
• Penetration Testing: The Platform undergoes regular third-party penetration testing and vulnerability assessments to identify and remediate security weaknesses.
• Incident Response: demo88 maintains a documented data breach incident response procedure. In the event of a breach that poses a risk to your rights and freedoms, we will notify affected players and relevant authorities within the timeframes required by applicable law.

11 Cookies & Tracking Technologies

demo88 uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device by a web server. Cookies are used on the Platform for the following purposes:

11.1 Strictly Necessary Cookies

These cookies are essential to the operation of the Platform and cannot be disabled. They include session cookies that maintain your authenticated login state, security tokens that protect against cross-site request forgery (CSRF), and load-balancing cookies that ensure consistent server performance. Without these cookies, core Platform functionality cannot operate.

11.2 Performance and Analytics Cookies

We use analytics cookies to understand how players navigate the Platform — which pages are visited most frequently, where users encounter errors, and how session duration correlates with product features. This data is aggregated and anonymized before analysis and is used solely to improve the Platform experience.

11.3 Functional Cookies

Functional cookies remember your preferences, such as your preferred language settings, last-visited game category, and display configuration choices. These are not strictly necessary but improve your experience by reducing the need to reconfigure settings on each visit.

11.4 Managing Cookies

You may configure your browser to reject or delete cookies at any time. Please note that disabling strictly necessary cookies will impair the functionality of the Platform and may prevent access to your account. Disabling performance or functional cookies will not affect your ability to use core services but may reduce the quality of your experience.

12 Your Data Rights

Subject to applicable law and any overriding legal obligations that demo88 must fulfill, you hold the following rights in relation to your personal data. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request" and your registered account username.

demo88 will respond to all verified data rights requests within thirty (30) calendar days of receipt. In complex cases requiring additional investigation, we may extend this period by a further two months, with written notification to you of the reason for the extension.

13 Minors and Age Restriction

The demo88 Platform is strictly intended for adults aged 21 years and over. We do not knowingly collect personal data from any person under the age of 21. If demo88 becomes aware that personal data has been collected from a minor, that account will be immediately suspended, all associated data will be securely deleted, and any funds deposited will be returned via the original payment method subject to identity verification.

Parents and guardians who believe a minor may have registered on the Platform are urged to contact our support team immediately at [email protected]. We treat such reports as a priority and will act within 24 hours of a verified report being received.

14 Third-Party Services and Links

The Platform integrates with third-party services including game content providers, payment gateways, and live streaming infrastructure. While demo88 carefully selects and vets all third-party partners, each third party operates under its own privacy policy and data practices. demo88 is not responsible for the data handling practices of third-party providers once data passes outside our direct control, except where governed by a binding data processing agreement.

Players are encouraged to review the privacy policies of any third-party service they interact with in connection with their use of demo88. If you have concerns about how a specific third-party integration handles your data, please contact our support team for clarification before proceeding.

15 Policy Amendments

demo88 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory guidance. Material amendments will be communicated to registered players via email notification prior to the effective date. A summary of key changes will be included in any such notification. The date displayed at the top of this page reflects the date on which the current version took effect. Your continued use of the Platform following the effective date of an updated Privacy Policy constitutes acceptance of the revised terms. If you do not agree to a material change, you may request account closure by contacting our support team before the effective date.

16 Contact & Data Protection Officer

If you have any questions, concerns, or complaints regarding this Privacy Policy or demo88's data handling practices, please contact us using the details below. Our data protection contact is available seven days a week and will acknowledge your inquiry within two business days.

• Email: [email protected] (plain text — not a clickable link)
• Subject Line for Data Requests: "Privacy Inquiry" or "Data Rights Request"
• Support Hours: 24/7 — Indonesian-speaking agents available at all times
• Response Time: Acknowledgment within 2 business days; full response within 30 calendar days

If you are not satisfied with demo88's response to a data-related complaint, you may have the right to escalate the matter to the applicable data protection supervisory authority or to seek judicial remedy under the laws of your jurisdiction.