Privacy Policy

1. Introduction and Scope

thr138 ("we", "us", "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you access or use our online betting platform at https://thr138.cam (the "Website") and associated services (collectively, the "Services").

This Privacy Policy applies to all users of thr138 Services, including visitors who browse the Website without registering and registered users who create accounts and participate in betting activities. By accessing or using thr138 Services, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your personal information as described in this Privacy Policy.

If you do not agree with the terms of this Privacy Policy, you must immediately discontinue use of thr138 Services. This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern your overall use of thr138 Services.

thr138 operates primarily in Indonesia and serves Indonesian users. This Privacy Policy is designed to comply with applicable Indonesian data protection laws and international best practices for online privacy and security.

2. Information We Collect

thr138 collects various types of information to provide, maintain, and improve our Services, ensure security and regulatory compliance, and personalize your gaming experience. The categories of information we collect include:

2.1 Information You Provide Directly

When you register for a thr138 account or use our Services, you voluntarily provide us with the following personal information:

• Account Registration Information: Full legal name, date of birth, gender, email address, mobile phone number, residential address, and chosen username and password.
• Identity Verification Documents: Government-issued identification (KTP - Indonesian National Identity Card, passport, or driver's license), proof of address documents, and payment method verification documents required for Know Your Customer (KYC) compliance.
• Financial Information: Bank account details (bank name, account number, account holder name), e-wallet account information (OVO, DANA, GoPay, ShopeePay, LinkAja), transaction history, deposit and withdrawal records, and betting activity records.
• Communication Data: Messages, emails, live chat transcripts, WhatsApp conversations, and any other communications you send to thr138 customer support.
• Voluntary Information: Any additional information you choose to provide through surveys, feedback forms, promotional participation, or direct communications with thr138 staff.

2.2 Information Collected Automatically

When you access or use thr138 Services, we automatically collect certain technical and usage information:

• Device Information: Device type, operating system and version, browser type and version, screen resolution, device identifiers, and mobile network information.
• Connection Information: IP address, internet service provider, approximate geographic location based on IP address, time zone setting, and connection timestamps.
• Usage Data: Pages visited, features used, games played, bets placed, time spent on the platform, click patterns, navigation paths, session duration, and interaction with promotional content.
• Performance Data: Application crash reports, error logs, page load times, and other technical performance metrics that help us improve service quality.

2.3 Information from Third Parties

thr138 may receive information about you from third-party sources, including:

• Payment Providers: Transaction verification data from Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon) and e-wallet services (OVO, DANA, GoPay, ShopeePay, LinkAja).
• Identity Verification Services: Age verification, identity authentication, and fraud prevention checks conducted by third-party verification providers.
• Game Providers: Gaming activity data and results from our third-party game suppliers (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, and others).
• Marketing Partners: Information about how you found thr138 (referral sources, affiliate links, advertising campaign data) if you arrived through marketing channels.

3. How We Use Your Information

thr138 uses the collected information for the following legitimate business purposes:

3.1 Service Provision and Account Management

• Create, maintain, and manage your thr138 user account.
• Process your registration and verify your eligibility to use our Services (including age verification to ensure you are 21 years or older).
• Authenticate your identity when you log in and access your account.
• Enable you to place bets, play games, and participate in promotions.
• Maintain your gaming history, transaction records, and account preferences.
• Provide customer support and respond to your inquiries, complaints, or feedback.

3.2 Financial Transactions and Payment Processing

• Process deposits into your thr138 account from Indonesian banks and e-wallets.
• Process withdrawal requests and transfer funds to your designated bank account or e-wallet.
• Verify ownership of payment methods and prevent fraudulent transactions.
• Calculate and credit bonuses, promotions, and loyalty rewards to your account.
• Generate financial records and transaction reports for regulatory compliance.

3.3 Security, Fraud Prevention, and Compliance

• Detect, investigate, and prevent fraudulent activity, collusion, money laundering, and other illegal conduct.
• Monitor for suspicious betting patterns or account abuse.
• Enforce our Terms & Conditions and prevent breaches of our rules.
• Comply with legal obligations under Indonesian law and international gaming regulations.
• Respond to lawful requests from government authorities, law enforcement, or regulatory bodies.
• Protect the security and integrity of thr138 Services against unauthorized access, hacking attempts, and technical vulnerabilities.

3.4 Responsible Gaming and Player Protection

• Monitor player behavior for signs of problem gambling.
• Enforce age restrictions and prevent underage gambling.
• Implement and manage self-exclusion requests, deposit limits, loss limits, and session time limits as described on our Responsible Gaming page.
• Provide targeted responsible gaming messages and resources to at-risk players.

3.5 Service Improvement and Personalization

• Analyze usage patterns to improve Website functionality, user interface, and overall user experience.
• Personalize content, game recommendations, and promotional offers based on your preferences and gaming history.
• Conduct market research, surveys, and data analysis to develop new features and services.
• Test new features, games, and platform enhancements.

3.6 Marketing and Communication

• Send promotional emails, SMS messages, or push notifications about bonuses, new games, tournaments, and special offers (only with your consent).
• Communicate important account updates, security alerts, and service changes.
• Provide customer newsletters, gaming tips, and responsible gaming information.
• Manage your communication preferences and honor opt-out requests.

4. Legal Basis for Processing

thr138 processes your personal information based on the following legal grounds:

• Contractual Necessity: Processing is necessary to fulfill our contractual obligations to you under the Terms & Conditions, including providing gaming services, processing transactions, and managing your account.
• Legal Compliance: Processing is required to comply with Indonesian law, gaming regulations, anti-money laundering requirements, age verification mandates, and responses to lawful government requests.
• Legitimate Interests: Processing serves thr138's legitimate business interests in operating a secure, reliable gaming platform, preventing fraud, ensuring fair play, improving services, and marketing to interested users—provided these interests do not override your fundamental rights and freedoms.
• Consent: For certain processing activities such as optional marketing communications, we rely on your explicit consent, which you may withdraw at any time.

5. Data Sharing and Disclosure

thr138 does not sell your personal information to third parties. However, we may share your information with the following categories of recipients for the purposes described in this Privacy Policy:

5.1 Service Providers and Business Partners

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) that process your deposits and withdrawals.
• Game Providers: Third-party software suppliers (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, and 50+ other providers) who deliver games on the thr138 platform and require certain user data to operate their games.
• Identity Verification Services: Third-party KYC (Know Your Customer) and age verification providers who help us confirm your identity and eligibility.
• Technical Infrastructure Providers: Cloud hosting services, content delivery networks, database management providers, and cybersecurity services that support thr138 platform operations.
• Customer Support Tools: Live chat platforms, ticketing systems, and communication service providers that enable our customer support operations.
• Analytics and Marketing Services: Analytics platforms that help us understand user behavior and marketing effectiveness (these services typically process anonymized or aggregated data).

All third-party service providers are contractually bound to protect your data, use it only for the purposes we specify, and maintain confidentiality in accordance with this Privacy Policy and applicable laws.

5.2 Legal and Regulatory Authorities

thr138 may disclose your personal information to government authorities, law enforcement agencies, regulatory bodies, or courts when:

• Required by Indonesian law, legal process, or valid governmental request.
• Necessary to investigate, prevent, or take action regarding suspected illegal activities, fraud, or violations of our Terms & Conditions.
• Required to protect the rights, property, or safety of thr138, our users, or the public.
• Necessary to comply with gaming licenses, anti-money laundering regulations, or tax reporting obligations.

5.3 Business Transfers

If thr138 undergoes a merger, acquisition, reorganization, sale of assets, or bankruptcy proceeding, your personal information may be transferred to the successor entity as part of the business transaction. In such cases, we will notify you via email or prominent notice on the Website, and the successor entity will remain bound by the terms of this Privacy Policy.

6. Data Security and Protection

thr138 takes the security of your personal information extremely seriously. We implement comprehensive technical and organizational measures to protect your data against unauthorized access, alteration, disclosure, or destruction:

6.1 Technical Security Measures

• 256-bit SSL Encryption: All data transmitted between your device and thr138 servers is encrypted using industry-standard Secure Socket Layer (SSL) technology with 256-bit encryption keys, the same level of security used by financial institutions worldwide.
• Secure Data Storage: Personal information is stored on secure servers located in professionally managed data centers with physical security controls, environmental monitoring, redundant power supplies, and disaster recovery capabilities.
• Access Controls: Strict role-based access controls ensure that only authorized thr138 personnel with a legitimate business need can access your personal information. All access is logged and monitored.
• Firewalls and Intrusion Detection: Enterprise-grade firewalls, intrusion detection systems, and intrusion prevention systems protect against unauthorized access attempts and cyber attacks.
• Regular Security Audits: thr138 conducts regular security assessments, vulnerability scans, and penetration testing to identify and remediate potential security weaknesses.
• Data Anonymization: Where possible, we anonymize or pseudonymize personal information used for analytics, reporting, and testing purposes to minimize privacy risks.

6.2 Organizational Security Measures

• Employee Training: All thr138 employees receive mandatory training on data protection, privacy best practices, and secure handling of customer information.
• Confidentiality Agreements: Employees and contractors with access to personal information sign strict confidentiality agreements and are bound by professional secrecy obligations.
• Incident Response Plan: We maintain a comprehensive data breach response plan to quickly detect, contain, and remediate any security incidents.
• Data Minimization: We collect and retain only the minimum personal information necessary to provide our Services and fulfill our legal obligations.

6.3 Your Security Responsibilities

While thr138 employs robust security measures, you also play a critical role in protecting your account:

• Choose a strong, unique password and never share it with anyone.
• Log out of your account after each session, especially on shared or public devices.
• Keep your contact information (email and mobile number) up to date so we can reach you with security alerts.
• Be cautious of phishing emails or messages claiming to be from thr138—we will never ask for your password via email.
• Report any suspicious account activity to customer support immediately.

7. Data Retention Period

thr138 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:

• Active Accounts: Personal information associated with active thr138 accounts is retained for the duration of the account's active status.
• Closed Accounts: After you close your account, we retain your personal information for a minimum of 5 years to comply with Indonesian financial record-keeping requirements, gaming regulations, tax obligations, and to resolve any disputes or claims that may arise.
• Self-Excluded Users: If you self-exclude from thr138, we retain your information for the duration of the self-exclusion period plus 5 years thereafter to enforce the exclusion and comply with responsible gaming regulations.
• Transaction Records: Financial transaction records (deposits, withdrawals, bets) are retained for 7 years to comply with anti-money laundering regulations and tax law requirements.
• Communication Records: Customer support communications are retained for 3 years for quality assurance, dispute resolution, and training purposes.
• Marketing Data: If you opt out of marketing communications, we retain minimal information (email address, opt-out status) indefinitely to honor your preferences and prevent future unwanted contact.

After the applicable retention period expires, thr138 will securely delete or anonymize your personal information in accordance with our data retention and destruction policies.

8. Your Privacy Rights

As a thr138 user, you have the following rights regarding your personal information:

8.1 Right of Access

You have the right to request confirmation of whether thr138 processes your personal information and to obtain a copy of your personal data. You can access most of your personal information directly through your account dashboard. For additional information not available through your account, contact customer support.

8.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You can update your contact details, address, and communication preferences directly in your account settings. For changes to your legal name or date of birth, contact customer support with supporting documentation.

8.3 Right to Erasure

You have the right to request deletion of your personal information in certain circumstances, subject to legal retention requirements. Note that we must retain certain information for regulatory compliance, fraud prevention, and legal purposes even after account closure. To request erasure, contact customer support and explain your request.

8.4 Right to Restrict Processing

You have the right to request that thr138 limit how we process your personal information in certain situations, such as while we verify the accuracy of disputed data or assess the legitimacy of a processing activity. Restrictions may impact your ability to use certain thr138 Services.

8.5 Right to Data Portability

You have the right to request a copy of your personal information in a structured, commonly used, machine-readable format for transfer to another service provider. Contact customer support to request data portability.

8.6 Right to Object

You have the right to object to processing of your personal information based on legitimate interests or for direct marketing purposes. You can opt out of marketing communications at any time through your account settings or by contacting customer support.

8.7 Right to Withdraw Consent

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

8.8 Exercising Your Rights

To exercise any of these privacy rights, contact thr138 customer support via:

• Email: [email protected]
• Live Chat: Available 24/7 on the thr138 Website
• WhatsApp: +62 812 3456 7890

We will respond to your request within 14 business days. We may request additional information to verify your identity before fulfilling certain requests to protect your privacy and security.

9. Cookies and Tracking Technologies

thr138 uses cookies, web beacons, and similar tracking technologies to enhance your experience, analyze usage patterns, and deliver personalized content. Cookies are small text files stored on your device that allow us to recognize you on return visits.

9.1 Types of Cookies We Use

• Essential Cookies: Necessary for the Website to function properly. These cookies enable core functionality such as security, account authentication, and session management. Essential cookies cannot be disabled.
• Performance Cookies: Collect anonymous information about how you use the Website, which pages are most popular, and error messages you encounter. This data helps us improve Website performance.
• Functional Cookies: Remember your preferences (such as language, region, or display settings) to provide a more personalized experience.
• Analytics Cookies: Help us understand user behavior through aggregated statistics, enabling us to improve our Services and content.
• Advertising Cookies: Track your activity across websites to deliver relevant advertisements and measure campaign effectiveness.

9.2 Managing Cookies

Most web browsers allow you to control cookies through browser settings. You can set your browser to refuse all cookies, accept only certain cookies, or notify you when a cookie is sent. Note that disabling cookies may impact your ability to use certain features of thr138 Services.

To learn more about cookies and how to manage them, visit www.allaboutcookies.org (educational resource, not affiliated with thr138).

10. Third-Party Services

thr138 Services may contain links to third-party websites, applications, or services (such as game providers, payment processors, or social media platforms). This Privacy Policy applies only to thr138 Services. We are not responsible for the privacy practices or content of third-party services.

When you access third-party services through thr138, you are subject to those third parties' privacy policies and terms of service. We encourage you to review the privacy policies of any third-party service you interact with to understand how they collect, use, and protect your information.

thr138 carefully selects reputable third-party partners and requires them to maintain appropriate data protection standards, but we cannot control their practices once you leave the thr138 platform.

11. International Data Transfers

thr138 primarily operates in Indonesia and stores user data within Indonesian territory or in secure data centers located in Southeast Asia. However, some of our third-party service providers (particularly game providers and technical infrastructure services) may be located in other countries, including the European Union, United States, or other regions.

When we transfer your personal information internationally, we ensure that appropriate safeguards are in place to protect your data in accordance with this Privacy Policy and applicable data protection laws. These safeguards may include:

• Contractual agreements with third-party processors requiring them to maintain equivalent data protection standards.
• Verification that the recipient country provides adequate data protection as recognized by Indonesian authorities.
• Use of standard contractual clauses or other approved transfer mechanisms.

12. Children's Privacy

thr138 Services are strictly intended for adults aged 21 years and older. We do not knowingly collect, use, or disclose personal information from individuals under 21 years of age. Online gambling by minors is illegal in Indonesia, and thr138 takes this prohibition extremely seriously.

If you are under 21 years old, you must not access, register for, or use thr138 Services. If you are a parent or guardian and believe your child has provided personal information to thr138, please contact us immediately at [email protected]. We will promptly investigate and delete such information from our systems.

thr138 employs age verification mechanisms during account registration and may request identity documents at any time to verify a user's age. Accounts found to belong to individuals under 21 will be immediately closed, and any funds will be returned in accordance with our Terms & Conditions.

13. Changes to This Privacy Policy

thr138 reserves the right to modify, amend, or update this Privacy Policy at any time to reflect changes in our practices, Services, legal requirements, or for other operational, regulatory, or business reasons. When we make changes, we will update the "Last Updated" date at the top of this document.

If we make material changes that significantly affect your privacy rights or how we use your personal information, we will notify you by:

• Posting a prominent notice on the thr138 homepage for at least 30 days.
• Sending an email notification to the email address registered to your account.
• Displaying an in-account notification upon your next login.

Your continued use of thr138 Services after the effective date of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the changes, you must stop using thr138 Services and may request account closure by contacting customer support.

We encourage you to review this Privacy Policy periodically to stay informed about how thr138 protects your privacy.

14. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or how thr138 handles your personal information, please contact our customer support team:

• Email: [email protected] (typical response time: 2-6 hours during business hours)
• Live Chat: Available 24/7 through the thr138 Website (average response time: under 2 minutes)
• WhatsApp: +62 812 3456 7890 (24/7 support in Indonesian and English)

For privacy-related inquiries, please use the subject line "Privacy Inquiry - [Your Account Username]" to ensure prompt routing to the appropriate team. We will investigate your concern and respond within 14 business days.