Privacy Policy

1. Introduction

At gengpg, we recognize that privacy and data security are fundamental rights. This Privacy Policy applies to all users of our platform, including visitors to our website https://gengpg.cam, registered account holders, and anyone who interacts with our services. We operate as an international gaming platform serving Indonesian players, and we adhere to both international data protection standards and local Indonesian privacy considerations.

This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern your use of our services. By accepting our Terms & Conditions, you also accept this Privacy Policy. If you do not agree with any aspect of this policy, you should not use our services or provide us with your personal information.

We may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or business operations. Any material changes will be communicated to you via email or through a prominent notice on our website. Your continued use of our services after such modifications constitutes your acceptance of the updated policy.

2. Information We Collect

2.1 Information You Provide Directly

When you register for a gengpg account, we collect the following personal information:

• Identity Information: Full legal name, date of birth, gender, nationality, and National Identity Card (KTP) number or passport number for Indonesian residents.
• Contact Information: Email address, phone number (mobile), residential address including street, city (such as Jakarta, Surabaya, Medan, Bandung, or Bali), postal code, and province.
• Financial Information: Bank account details (account number, account holder name, bank name such as BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP), e-wallet account details (OVO, DANA, GoPay, ShopeePay, LinkAja), and transaction history.
• Verification Documents: Scanned copies or photographs of your KTP, utility bills, bank statements, and selfie photographs for identity verification (KYC) purposes.
• Account Credentials: Username, password (stored in encrypted form), and security questions/answers.

2.2 Information Collected Automatically

When you access our website or use our services, we automatically collect certain technical information:

• Device Information: Device type (mobile, tablet, desktop), operating system (iOS, Android, Windows, macOS), browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited, features used, games played, bet amounts, win/loss records, session duration, click patterns, and navigation paths through our website.
• Network Information: IP address, internet service provider (ISP), approximate geographic location (city/region level, not precise GPS coordinates), connection type, and network performance data.
• Cookies and Similar Technologies: We use cookies, web beacons, pixel tags, and local storage to track user preferences, maintain login sessions, and analyze website performance. See Section 8 for detailed information about cookies.

2.3 Information from Third Parties

We may receive information about you from third-party sources, including:

• Payment Processors: Transaction confirmation data from Indonesian banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay) to verify deposits and process withdrawals.
• Game Providers: Gameplay data, bet records, and win/loss information from third-party game developers such as Pragmatic Play, Evolution Gaming, NetEnt, and Microgaming.
• Identity Verification Services: Verification results from KYC service providers that confirm the authenticity of your identity documents and detect fraudulent activity.
• Marketing Partners: Aggregated demographic and interest data (not personally identifiable) from advertising platforms to help us understand our audience.

3. How We Use Your Information

gengpg collects and processes your personal information for the following legitimate business purposes:

3.1 Account Management and Service Provision

• Creating and maintaining your user account.
• Verifying your identity and age (21+ requirement) to comply with legal obligations.
• Processing deposits, withdrawals, and other financial transactions.
• Providing customer support via live chat, email, and WhatsApp.
• Enabling you to participate in casino games, sports betting, lottery products, and other gaming services.
• Maintaining accurate records of your gameplay history, transaction history, and account activity.

3.2 Legal Compliance and Fraud Prevention

• Complying with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations required by international gaming authorities.
• Detecting and preventing fraudulent activity, bonus abuse, money laundering, identity theft, and other illegal activities.
• Monitoring gameplay patterns to identify cheating, collusion, use of bots or automated software, and exploitation of software vulnerabilities.
• Responding to legal requests from law enforcement agencies, regulatory bodies, or courts of competent jurisdiction.
• Enforcing our Terms & Conditions and protecting our legal rights.

3.3 Marketing and Communications

• Sending you promotional offers, bonus announcements, and information about new games or features (only if you have consented to receive marketing communications).
• Personalizing your user experience based on your gaming preferences and activity history.
• Conducting customer satisfaction surveys and market research to improve our services.
• Sending transactional emails such as account verification confirmations, withdrawal notifications, and password reset instructions (these are mandatory service communications and cannot be opted out of).

3.4 Platform Improvement and Analytics

• Analyzing user behavior and website performance to optimize our platform's functionality, speed, and user interface.
• Conducting A/B testing to improve website design and feature effectiveness.
• Identifying technical issues, bugs, and system errors to maintain platform stability.
• Developing new features, games, and services based on user demand and industry trends.

4. Data Sharing and Third Parties

gengpg does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your data with the following categories of third parties under specific circumstances:

4.1 Service Providers and Business Partners

• Payment Processors: We share necessary financial information with Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to process deposits and withdrawals. These providers operate under their own privacy policies and security standards.
• Game Providers: Your account identifier, bet amounts, and gameplay data are shared with third-party game developers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe) to enable game functionality and maintain accurate records.
• KYC Verification Services: We use third-party identity verification providers to authenticate your identity documents, detect forged documents, and comply with AML regulations. These providers have access to your KTP, utility bills, and selfie photographs.
• Customer Support Platforms: Our live chat, email ticketing, and WhatsApp support systems are hosted by third-party customer service platforms that process your support inquiries and chat transcripts.
• Analytics Providers: We use analytics services to understand website traffic patterns, user demographics, and platform performance. These providers receive anonymized or pseudonymized data that does not directly identify you.

4.2 Legal and Regulatory Authorities

We may disclose your personal information to law enforcement agencies, regulatory bodies, courts, or government authorities if:

• We are legally required to do so by a valid court order, subpoena, or legal process.
• We believe disclosure is necessary to prevent fraud, money laundering, or other illegal activity.
• Disclosure is required to protect the rights, property, or safety of gengpg, our users, or the public.
• We are obligated to report suspicious transactions under AML regulations.

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the successor entity as part of the business transaction. We will notify you via email and/or a prominent notice on our website if your data will be subject to a different privacy policy as a result of such a transfer.

4.4 With Your Consent

We may share your information with third parties for purposes not described in this Privacy Policy if we obtain your explicit consent at the time of collection.

5. Data Security Measures

gengpg employs industry-standard security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. Our security infrastructure includes:

5.1 Technical Security Controls

• SSL/TLS Encryption: All data transmitted between your browser and our servers is encrypted using 256-bit SSL (Secure Socket Layer) encryption, the same standard used by major Indonesian banks like BCA, BRI, and Mandiri.
• Data Encryption at Rest: Sensitive data stored in our databases, including passwords, financial information, and identity documents, is encrypted using AES-256 encryption.
• Secure Payment Processing: We use PCI DSS-compliant payment gateways to process transactions. We do not store your full bank account numbers or credit card details on our servers.
• Firewall Protection: Our servers are protected by enterprise-grade firewalls that block unauthorized access attempts and network intrusions.
• DDoS Protection: We employ distributed denial-of-service (DDoS) mitigation services to ensure platform availability during attacks.

5.2 Organizational Security Measures

• Access Controls: Only authorized gengpg employees with a legitimate business need have access to personal information. All staff members sign confidentiality agreements and receive data protection training.
• Regular Security Audits: We conduct periodic security assessments, vulnerability scans, and penetration testing to identify and address potential weaknesses.
• Incident Response Plan: We maintain a data breach response protocol that includes user notification, regulatory reporting, and remediation measures in the event of a security incident.
• Secure Development Practices: Our engineering team follows secure coding standards and conducts code reviews to prevent vulnerabilities such as SQL injection, cross-site scripting (XSS), and cross-site request forgery (CSRF).

5.3 Your Role in Security

While we implement robust security measures, you also play a critical role in protecting your account:

• Use a strong, unique password for your gengpg account. Avoid using the same password across multiple websites.
• Never share your login credentials, password, or security questions with anyone, including individuals claiming to be gengpg support staff.
• Log out of your account when using shared or public computers.
• Report any suspicious account activity to our customer support team immediately.
• Ensure your registered email account is secure, as it is used for password resets and important account notifications.

6. Data Retention and Deletion

gengpg retains your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

6.1 Retention Periods

• Active Accounts: Your account information, transaction history, and gameplay records are retained for the duration of your active account relationship with gengpg.
• Closed Accounts: After you close your account, we retain your personal information for a minimum of 5 years to comply with international AML regulations, tax reporting requirements, and legal obligations. This retention period allows us to respond to legal inquiries, resolve disputes, and prevent fraud.
• Marketing Data: If you opt out of marketing communications, we will retain your email address on a suppression list to ensure you do not receive future marketing emails, but we will not use it for any other purpose.
• Security Logs: IP addresses, login timestamps, and security event logs are retained for up to 2 years for fraud detection and investigation purposes.

6.2 Data Deletion

After the applicable retention period expires, we securely delete or anonymize your personal information in accordance with data protection best practices. Deletion methods include:

• Overwriting data multiple times to ensure it cannot be recovered.
• Physically destroying hard drives and backup media containing personal information.
• Anonymizing data by removing personally identifiable fields, rendering the data non-reversible.

Please note that certain information may persist in archived backup systems for a limited period after deletion from active databases. These backups are stored securely and are not accessible for normal business operations.

7. Your Privacy Rights

As a gengpg user, you have the following rights regarding your personal information:

7.1 Right to Access

You have the right to request a copy of the personal information we hold about you. This includes your account details, transaction history, verification documents, and communication records. To request access, contact our customer support team at [email protected] with your account details. We will respond to your request within 30 days.

7.2 Right to Rectification

If any personal information we hold about you is inaccurate, incomplete, or outdated, you have the right to request correction. You can update most information directly through your account settings, or contact customer support for assistance with changes to verified information such as your name or date of birth.

7.3 Right to Deletion (Right to be Forgotten)

You have the right to request deletion of your personal information, subject to certain legal limitations. We may be required to retain certain data to comply with AML regulations, tax laws, or to resolve ongoing disputes. If you wish to delete your account and data, contact customer support. Please note that account deletion is irreversible, and any remaining funds must be withdrawn before deletion.

7.4 Right to Object to Processing

You have the right to object to certain types of data processing, particularly for marketing purposes. You can opt out of promotional emails by clicking the "unsubscribe" link in any marketing email, or by updating your communication preferences in your account settings.

7.5 Right to Data Portability

You have the right to request a copy of your personal information in a structured, machine-readable format (such as CSV or JSON) that can be transferred to another service provider. To request data portability, contact customer support.

7.6 Right to Withdraw Consent

If we process your personal information based on your consent (such as marketing communications), you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing conducted before the withdrawal.

8. Cookies and Tracking Technologies

gengpg uses cookies and similar tracking technologies to enhance your user experience, analyze website performance, and deliver personalized content.

8.1 What Are Cookies?

Cookies are small text files stored on your device by your web browser when you visit our website. Cookies allow us to recognize your device, remember your preferences, and track your activity across sessions.

8.2 Types of Cookies We Use

• Essential Cookies: These cookies are necessary for the website to function properly. They enable core features such as user authentication, account login sessions, and secure payment processing. You cannot opt out of essential cookies without affecting website functionality.
• Performance Cookies: These cookies collect anonymous information about how users interact with our website, such as page views, traffic sources, and error messages. We use this data to improve website performance and user experience.
• Functionality Cookies: These cookies remember your preferences, such as language settings, preferred currency (IDR), and display options, to provide a personalized experience.
• Marketing Cookies: These cookies track your browsing behavior across websites to deliver targeted advertisements and measure the effectiveness of our marketing campaigns. Marketing cookies may be set by third-party advertising networks.

8.3 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can choose to block or delete cookies, but doing so may affect your ability to use certain features of our website. To manage cookies, consult your browser's help documentation (Chrome, Firefox, Safari, Edge).

9. International Data Transfers

gengpg operates as an international gaming platform with servers and service providers located in multiple jurisdictions outside Indonesia. When you use our services, your personal information may be transferred to, stored in, and processed in countries that may have different data protection laws than Indonesia.

We take steps to ensure that your personal information receives an adequate level of protection when transferred internationally, including:

• Transferring data only to countries recognized as providing adequate data protection.
• Using contractual clauses approved by international data protection authorities that require recipient parties to protect your data.
• Ensuring that service providers adhere to internationally recognized data protection frameworks and standards.

By using gengpg's services, you consent to the international transfer of your personal information as described in this section.

10. Changes to This Privacy Policy

gengpg reserves the right to update, modify, or replace this Privacy Policy at any time. Changes may be made to reflect new legal requirements, evolving data protection standards, changes to our business operations, or improvements to our data practices.

When we make material changes to this Privacy Policy, we will notify you by:

• Sending an email to the email address registered on your account.
• Displaying a prominent notice on our website homepage.
• Updating the "Last Updated" date at the top of this page.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of our services after changes to this Privacy Policy constitutes your acceptance of the revised policy.

11. Contact Us About Privacy

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal information, please contact our Data Protection Team:

• Email: [email protected]
• Subject Line: "Privacy Inquiry" or "Data Protection Request"
• Live Chat: Available 24/7 through your gengpg account dashboard

Our customer support team will respond to privacy-related inquiries within 30 days. For complex requests such as data access, deletion, or portability, we may require additional time to verify your identity and fulfill the request.

If you believe that we have not adequately addressed your privacy concerns, you may have the right to lodge a complaint with a data protection authority in your jurisdiction. However, we encourage you to contact us first so we can attempt to resolve your concerns directly.