Privacy Policy — kera3

1 Introduction

kera3 operates as an internationally licensed online gaming platform serving the Indonesian market. We are committed to protecting the privacy and security of your personal data in accordance with international data protection standards and the regulatory requirements of our licensing jurisdiction. This Privacy Policy is designed to help you understand what personal data we collect, why we collect it, how we use it, and what choices you have regarding your data.

We recognise that trust is fundamental to our relationship with our players. Transparent data handling practices are central to earning and maintaining that trust. This Policy should be read in conjunction with our Terms & Conditions, which govern your use of the kera3 Platform.

2 Definitions

For the purposes of this Privacy Policy, the following terms have the meanings set forth below:

• "Personal Data" means any information relating to an identified or identifiable natural person ("Data Subject"). This includes but is not limited to name, date of birth, address, email address, phone number, government-issued identification numbers, financial account details, IP address, device identifiers, and transaction history.
• "Processing" means any operation performed on Personal Data, whether automated or manual, including collection, recording, organisation, storage, alteration, retrieval, consultation, use, disclosure, transmission, erasure, or destruction.
• "Data Controller" means the entity that determines the purposes and means of Processing Personal Data. For the purposes of this Policy, kera3 is the Data Controller.
• "Data Processor" means any third-party entity that Processes Personal Data on behalf of the Data Controller in accordance with the Controller's instructions.
• "Platform" means the kera3 website accessible at kera3.cam and all associated mobile interfaces, APIs, and integrated services.
• "Cookies" means small text files placed on your device by a website to store information about your browsing activity, preferences, and session state.

3 Data Controller

kera3, operating under its international gaming licence, is the Data Controller responsible for your Personal Data. All enquiries, requests, or complaints regarding the Processing of your Personal Data should be directed to our Data Protection Officer via email at [email protected] with the subject line "Privacy Enquiry".

4 Data We Collect

kera3 collects several categories of Personal Data to operate the Platform, provide gaming services, comply with legal obligations, and improve user experience. The types of Personal Data we collect include:

4.1 Account Registration Data

When you register for a kera3 Account, we collect:

• Full legal name as it appears on your government-issued identification
• Date of birth
• Residential address (street, city, province, postal code)
• Email address
• Mobile phone number
• Preferred username and password (password is stored in hashed, non-reversible format)
• Preferred currency (Indonesian Rupiah / IDR)

4.2 Identity Verification (KYC) Data

To comply with anti-money laundering (AML) and Know Your Customer (KYC) regulations, we collect:

• Government-issued photo identification (KTP — Kartu Tanda Penduduk — for Indonesian residents, or passport)
• Selfie photographs holding your identification document
• Proof of address documents (utility bills, bank statements)
• Proof of payment method ownership (bank account statements, e-wallet screenshots showing registered name and account/phone number)
• In cases requiring enhanced due diligence, documentation verifying the source of deposited funds

4.3 Financial Transaction Data

We collect data related to your deposits, withdrawals, and wagering activity, including:

• Bank account details (bank name, account holder name, account number) for BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, and other supported Indonesian banks
• E-wallet account details (OVO, DANA, GoPay, ShopeePay, LinkAja phone numbers or account identifiers)
• Deposit amounts, dates, times, and transaction reference numbers
• Withdrawal requests, processing times, and completion records
• Player Balance history and bonus fund allocations

4.4 Gameplay and Wagering Data

We automatically log all gaming activity on your Account, including:

• Wagers placed (bet type, stake amount, odds, selection)
• Game sessions (start time, end time, game type, session duration)
• Win/loss outcomes and settlement records
• Bonus claims, wagering requirement progress, and bonus expirations
• Responsible gaming settings (deposit limits, session time limits, self-exclusion requests)

4.5 Technical and Device Data

When you access the kera3 Platform, we automatically collect technical information, including:

• IP address and geolocation data (city-level, not precise GPS coordinates)
• Device type, operating system, browser type and version
• Screen resolution, language settings, time zone (WIB, WITA, or WIT)
• Referring URL (the website you visited immediately before arriving at kera3.cam)
• Pages visited, time spent on each page, click patterns, and navigation paths
• Session cookies and persistent cookies (see Section 12 for details)

4.6 Communications Data

We retain records of all communications between you and kera3, including:

• Live chat transcripts with customer support agents
• Email correspondence sent to or received from [email protected]
• Telephone call recordings (where call recording is implemented and disclosed)
• Feedback forms, surveys, and complaint submissions

5 How We Collect Data

kera3 collects Personal Data through the following methods:

• Direct Collection: Information you provide directly to us during Account registration, KYC submission, deposit/withdrawal processing, or customer support interactions.
• Automated Collection: Technical data collected automatically via cookies, server logs, and analytics tools when you access the Platform.
• Third-Party Sources: Payment processors (banks, e-wallet providers) may share limited transaction data to confirm payment completion. Identity verification services may share KYC validation results. Game providers (Pragmatic Play, Evolution Gaming, etc.) share game outcome data.

6 Purpose of Processing

kera3 Processes your Personal Data for the following purposes:

• Account Management: Creating and maintaining your Player Account, authenticating your identity, and managing login sessions.
• Service Delivery: Processing deposits and withdrawals, crediting winnings, applying bonuses, and facilitating gameplay across sports betting, casino, slots, togel, and crash games.
• Compliance and KYC: Verifying your identity and age to comply with anti-money laundering (AML), counter-terrorism financing (CTF), and responsible gaming regulations mandated by our licensing jurisdiction.
• Fraud Prevention: Detecting and preventing fraudulent activity, duplicate accounts, bonus abuse, collusion, and unauthorised access.
• Customer Support: Responding to enquiries, resolving disputes, and providing technical assistance via live chat, email, or phone.
• Responsible Gaming: Implementing deposit limits, session time controls, self-exclusion requests, and identifying players who may be at risk of problem gambling.
• Marketing Communications: Sending promotional offers, bonus announcements, and product updates to players who have opted in to receive marketing emails (opt-out available at any time).
• Platform Improvement: Analysing user behaviour, identifying technical issues, optimising website performance, and developing new features.
• Legal Obligations: Complying with court orders, regulatory reporting requirements, tax obligations, and law enforcement requests.

7 Legal Basis for Processing

kera3 Processes your Personal Data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and kera3 as set out in our Terms & Conditions. This includes account management, transaction processing, and service delivery.
• Legal Obligation: Processing is necessary to comply with legal obligations imposed on kera3 by our licensing authority, AML/CTF regulations, tax laws, and court orders.
• Legitimate Interests: Processing is necessary for kera3's legitimate business interests, including fraud prevention, platform security, customer support, and service improvement, provided that such interests are not overridden by your fundamental rights and freedoms.
• Consent: Where required by law, we obtain your explicit consent before Processing certain categories of Personal Data, such as marketing communications and the use of non-essential cookies.

8 Data Sharing and Disclosure

kera3 does not sell, rent, or trade your Personal Data to third-party marketers or data brokers. However, we do share Personal Data with the following categories of third parties in limited circumstances:

8.1 Service Providers (Data Processors)

We engage trusted third-party service providers to perform functions on our behalf, including:

• Payment processors and financial institutions (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, LinkAja) to process deposits and withdrawals
• Identity verification and KYC service providers to validate government-issued identification documents
• Cloud hosting providers to store data on secure servers
• Customer support platform providers to manage live chat and email ticketing systems
• Analytics providers to monitor Platform performance and user behaviour

All service providers are contractually bound to Process your Personal Data only in accordance with our instructions and to implement appropriate technical and organisational security measures.

8.2 Game Providers

When you play games from third-party studios (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft), limited session data (Player ID, wager amounts, game outcomes) is shared with those providers to facilitate gameplay. Game providers are bound by their own privacy policies and data protection obligations.

8.3 Regulatory Authorities

kera3 may disclose Personal Data to our licensing authority, financial regulators, and law enforcement agencies when required by law, court order, or regulatory investigation.

8.4 Legal and Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of assets, your Personal Data may be transferred to the acquiring entity, subject to the same privacy protections outlined in this Policy.

9 Data Retention

kera3 retains your Personal Data for as long as your Account remains active and for such additional period as is necessary to comply with legal obligations, resolve disputes, enforce our Terms & Conditions, and prevent fraud. Specific retention periods include:

• Active Accounts: All Personal Data is retained for the duration of your active Account.
• Closed Accounts: Following voluntary account closure, Personal Data is retained for a minimum of five (5) years to comply with AML/CTF regulatory requirements and licensing obligations. After this period, data is securely deleted or anonymised.
• KYC Documents: Identification documents and verification records are retained for seven (7) years from the date of account closure as required by international AML standards.
• Financial Records: Transaction history, deposit/withdrawal records, and tax-related documents are retained for seven (7) years to comply with financial audit and tax reporting obligations.
• Marketing Data: If you opt out of marketing communications, your email address is retained on a suppression list indefinitely to ensure you do not receive further marketing emails.
• Technical Logs: Server logs, IP address records, and session data are typically retained for ninety (90) days for security monitoring and troubleshooting purposes.

10 Data Security

kera3 employs industry-standard technical and organisational measures to protect your Personal Data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Our security measures include:

• Encryption: All Personal Data transmitted between your device and kera3 servers is encrypted using 256-bit SSL/TLS protocols. Passwords are hashed using bcrypt or Argon2 algorithms and are never stored in plaintext.
• Secure Data Centers: Personal Data is stored on secure servers located in jurisdictions with robust data protection laws. Physical access to data centers is restricted and monitored 24/7.
• Firewall Protection: Multi-layered firewall systems prevent unauthorised network access and protect against distributed denial-of-service (DDoS) attacks.
• Access Controls: Access to Personal Data is restricted to authorised kera3 employees and contractors on a need-to-know basis. All access is logged and audited.
• Regular Security Audits: kera3 conducts periodic security assessments, vulnerability scans, and penetration testing to identify and remediate potential security weaknesses.
• Incident Response Plan: In the event of a data breach, kera3 has established procedures to contain the breach, assess its impact, notify affected individuals, and report the incident to relevant authorities within the timeframes required by law.

While kera3 takes data security seriously, no method of transmission over the internet or electronic storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and should notify us immediately at [email protected] if you suspect unauthorised access to your Account.

11 Your Privacy Rights

Depending on your jurisdiction and applicable data protection laws, you may have the following rights regarding your Personal Data:

• Right of Access: You have the right to request a copy of the Personal Data we hold about you. We will provide this information in a structured, commonly used, and machine-readable format (typically PDF or CSV).
• Right to Rectification: If any Personal Data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it.
• Right to Erasure ("Right to be Forgotten"): You may request that we delete your Personal Data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, or when you withdraw consent. Note that we may be legally required to retain certain data for regulatory compliance purposes even after you request deletion.
• Right to Restriction of Processing: You may request that we limit the Processing of your Personal Data in certain situations, such as when you contest the accuracy of the data or when Processing is unlawful but you do not want the data deleted.
• Right to Data Portability: You have the right to receive your Personal Data in a portable format and to request that we transmit it directly to another controller where technically feasible.
• Right to Object: You may object to the Processing of your Personal Data for direct marketing purposes at any time. You may also object to Processing based on legitimate interests, in which case we will cease Processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where Processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of Processing based on consent before its withdrawal.
• Right to Lodge a Complaint: If you believe that kera3 has violated your privacy rights, you have the right to lodge a complaint with the data protection authority in your jurisdiction or in the jurisdiction where kera3's Data Controller is established.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with the subject line "Privacy Rights Request". We will respond to your request within thirty (30) days. In some cases, we may require additional information to verify your identity before fulfilling your request.

12 Cookies and Tracking Technologies

kera3 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyse usage patterns, and deliver personalised content. A cookie is a small text file stored on your device that allows us to recognise your browser and remember certain information about your session.

12.1 Types of Cookies We Use

• Essential Cookies: These cookies are strictly necessary for the operation of the Platform. They enable core functionality such as login authentication, session management, and secure transaction processing. Essential cookies cannot be disabled without impairing the Platform's functionality.
• Performance and Analytics Cookies: These cookies collect information about how you use the Platform, such as which pages you visit, how long you stay on each page, and any error messages you encounter. This data is aggregated and anonymised and is used to improve Platform performance.
• Functional Cookies: These cookies remember your preferences (such as language settings, currency selection, and user interface customisations) to provide a more personalised experience.
• Marketing and Advertising Cookies: These cookies track your browsing activity across the Platform to deliver targeted promotional content and measure the effectiveness of marketing campaigns. You can opt out of marketing cookies via your browser settings or the cookie consent banner displayed on your first visit.

12.2 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can configure your browser to block all cookies, accept only certain cookies, or notify you when a cookie is being set. Note that blocking essential cookies will prevent you from accessing certain features of the Platform, including login and transaction processing. For more information on managing cookies, consult your browser's help documentation.

13 Marketing Communications

With your consent, kera3 may send you promotional emails containing bonus offers, new game announcements, and other marketing content. You may opt out of marketing communications at any time by:

• Clicking the "Unsubscribe" link at the bottom of any marketing email
• Updating your communication preferences in your Account settings
• Contacting [email protected] with the subject line "Unsubscribe from Marketing"

Please note that even if you opt out of marketing communications, you will continue to receive transactional emails related to your Account, such as deposit confirmations, withdrawal notifications, and important security alerts. These transactional emails are essential to the operation of your Account and cannot be opted out of.

14 International Data Transfers

kera3 operates as an internationally licensed platform. Your Personal Data may be transferred to, stored in, and Processed in jurisdictions outside of Indonesia, including jurisdictions that may not offer the same level of data protection as Indonesian law. When we transfer Personal Data internationally, we implement appropriate safeguards, including:

• Standard Contractual Clauses (SCCs) approved by relevant data protection authorities
• Adequacy decisions recognising that the recipient jurisdiction provides an adequate level of data protection
• Binding Corporate Rules (BCRs) where transfers occur within a corporate group

By using the kera3 Platform, you consent to the international transfer of your Personal Data as described in this Policy.

15 Children's Privacy

kera3 strictly prohibits the use of its Platform by individuals under the age of 21. We do not knowingly collect Personal Data from persons under 21 years of age. If we become aware that we have inadvertently collected Personal Data from a minor, we will take immediate steps to delete that data and permanently close the associated Account. If you believe that kera3 has collected information from a person under 21, please contact us immediately at [email protected].

16 Changes to This Privacy Policy

kera3 reserves the right to amend, modify, or update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or operational needs. Any changes will be published on this page with an updated "Effective Date" at the top of the document. Material changes that significantly affect how we Process your Personal Data will be communicated via email or prominent on-Platform notice.

Your continued use of the kera3 Platform following the posting of a revised Privacy Policy constitutes your acceptance of those changes. We encourage you to review this Policy periodically to stay informed about how we are protecting your Personal Data.

17 Contact Information

For questions, concerns, or requests related to this Privacy Policy or the Processing of your Personal Data, you may contact kera3's Data Protection Officer via the following channels:

• Email: [email protected] (Subject: "Privacy Enquiry")
• Live Chat: Available 24/7 via the kera3 website interface
• Response Time: We aim to respond to all privacy-related enquiries within forty-eight (48) hours

If you are not satisfied with our response, you have the right to lodge a complaint with the data protection authority in your jurisdiction.

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