Privacy Policy — 55com

Data Controller

The data controller responsible for the personal information you provide when using the 55com platform is the legal entity operating 55com as an international online entertainment service. References to "55com", "we", "us", and "our" throughout this Privacy Policy refer to that operating entity. The full legal name and registered address of the data controller are available upon written request to our Data Protection Officer at the contact details provided in Clause 15 of this Policy.

By creating a 55com Account, depositing funds, placing bets, or otherwise using the 55com platform, you acknowledge that your personal data will be processed in accordance with the terms set out in this Privacy Policy. If you do not agree with this Policy, you must not use the 55com platform.

Data We Collect

55com collects personal data in several categories depending on your level of engagement with the platform. The following table summarizes the categories of personal data we may collect and hold:

We do not collect special categories of sensitive personal data — such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data beyond the identity liveness check required for KYC — unless you voluntarily disclose such information during a support interaction or responsible gaming assessment.

How We Collect Your Data

55com collects personal data through the following channels and mechanisms:

• Direct Registration: When you create a 55com Account, you directly provide your name, date of birth, email address, and mobile number. This is the primary source of your Identity and Contact Data.
• KYC Submission: When you submit identity documents to unlock withdrawal privileges, you directly provide Identity Verification Documents including scans or photographs of your Indonesian government-issued identification.
• Deposits and Withdrawals: When you conduct financial transactions through the 55com cashier using Indonesian bank transfers or e-wallets, Financial Data is collected automatically as part of the payment confirmation process.
• Platform Interaction: As you browse the 55com platform, place bets, play games, and navigate menus, Usage Data and Technical Data are collected automatically through server logs, cookies, and session-tracking technologies described in Clause 7.
• Support Contacts: When you contact 55com via live chat, email at [email protected], or phone, we collect and retain Communications Data as a record of the interaction.
• Third-Party Payment Processors: Our payment partners — including the Indonesian banking network operators and e-wallet providers OVO, DANA, GoPay, ShopeePay, and LinkAja — may share transaction confirmation data with 55com to reconcile deposits and withdrawals. These processors operate under their own privacy policies and are subject to Indonesian banking regulations.
• Game Content Providers: Third-party game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may transmit anonymized or pseudonymized gameplay session data to 55com for the purpose of RTP auditing, jackpot reconciliation, and technical support.

Legal Basis for Processing

55com processes your personal data only where we have a valid legal basis to do so. The applicable legal bases for our processing activities are:

• Contractual Necessity: The majority of data processing by 55com is necessary to perform the contract between you and 55com — specifically, to operate your Account, process deposits and withdrawals, credit bonuses, and deliver gaming services. Without this processing, we cannot provide the platform.
• Legal Obligation: 55com is required under international gaming regulations and anti-money laundering (AML) frameworks to collect and retain identity, financial, and transaction data. KYC verification and transaction monitoring are mandatory legal obligations, not optional activities.
• Legitimate Interests: 55com processes Technical Data and Usage Data on the basis of legitimate interests — specifically, to detect and prevent fraud, ensure platform security, monitor for problem gambling indicators, and improve platform performance. These interests are balanced against your privacy rights and do not override them.
• Consent: Where 55com sends you promotional communications, personalized bonus offers, or optional marketing emails, we rely on your explicit consent. You may withdraw this consent at any time by contacting support or updating your Account preferences. Withdrawal of marketing consent does not affect the lawfulness of any processing carried out before withdrawal.

How We Use Your Data

55com uses the personal data we collect for the following specific purposes:

• Account Management: Creating, verifying, operating, and closing your 55com Member Account; communicating account-critical notifications such as deposit confirmations, withdrawal updates, and security alerts.
• Identity & Age Verification: Confirming that all 55com Members are natural persons aged 21 years or older in accordance with our mandatory age policy and applicable regulations. Indonesia residents must be at minimum 21 years of age to hold a 55com Account.
• Payment Processing: Executing and reconciling deposits and withdrawals in Indonesian Rupiah (IDR / Rp) through local bank channels and e-wallet providers; issuing refunds where applicable; investigating disputed transactions.
• Fraud Prevention & Security: Monitoring login activity, transaction patterns, and gameplay behavior for indicators of unauthorized access, account takeover, bonus abuse, or financial crime. Geographic anomaly detection, device fingerprinting, and session analysis are applied for this purpose.
• Responsible Gaming: Analyzing Usage Data to identify behavioral patterns associated with problem gambling; proactively contacting Members who exhibit high-risk patterns; enforcing deposit limits, loss limits, session limits, and self-exclusion periods requested by Members.
• Regulatory Compliance: Fulfilling AML and counter-terrorism financing (CTF) obligations by maintaining transaction records, submitting required regulatory reports, and cooperating with lawful requests from competent authorities.
• Platform Improvement: Using aggregated and anonymized Usage Data to analyze platform performance, identify popular game categories, optimize page layouts, and improve the overall player experience on the 55com platform.
• Promotional Communications: Sending eligible Members information about bonus offers, seasonal promotions tied to the Indonesian cultural calendar (Ramadhan, Idul Fitri, Indonesian Independence Day, Imlek), and new game launches — where you have provided marketing consent.
• Customer Support: Investigating and resolving complaints, answering Account queries, and providing 24/7 assistance via live chat, email, and phone in both English and Indonesian.

Data Sharing & Disclosure

55com shares your personal data only in the following limited and controlled circumstances:

• Payment Processors & Banking Partners: To process deposits and withdrawals, 55com transmits the minimum necessary financial data to our Indonesian banking partners (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja). These entities are contractually bound to handle your data securely and use it solely for transaction processing.
• KYC & Identity Verification Providers: 55com uses third-party identity verification platforms to process government-issued ID documents and liveness check images. These providers are certified and operate under strict data processing agreements with 55com. Identity documents are not retained beyond the period required for verification and regulatory record-keeping.
• Game Studio Technology Partners: Third-party game providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive anonymized or pseudonymized session identifiers — not your personal name or financial data — for the purpose of game result verification, jackpot calculation, and technical support.
• Fraud Prevention & AML Networks: Where legally required or where we have a legitimate interest in preventing financial crime, 55com may share relevant transaction data with shared-risk fraud prevention services, international AML compliance databases, or financial intelligence units.
• Legal & Regulatory Authorities: 55com will disclose personal data to law enforcement agencies, regulatory authorities, courts, or other competent public bodies when required to do so by applicable law, court order, or regulatory direction. We will notify you of such disclosure unless we are legally prohibited from doing so.
• Corporate Restructuring: In the event of a merger, acquisition, asset sale, or reorganization involving the 55com operating entity, your personal data may be transferred to the acquiring or successor entity. You will be notified of any such transfer in advance, and the successor entity will be bound by terms no less protective than this Privacy Policy.
• Professional Advisers: 55com's legal counsel, auditors, and compliance advisers may access limited personal data on a strictly need-to-know basis as part of their professional engagement with 55com. All such advisers operate under professional confidentiality obligations.

Cookies & Tracking Technologies

55com uses cookies and similar tracking technologies — including web beacons, pixel tags, and local storage objects — to deliver a functional, secure, and personalized platform experience. The cookies deployed on the 55com platform fall into the following categories:

• Strictly Necessary Cookies: These cookies are essential for the 55com platform to function. They maintain your login session, remember your Account preferences during a session, and enable core security features including CSRF protection. You cannot opt out of strictly necessary cookies while using the platform.
• Performance Cookies: These cookies collect anonymized data about how Members use the 55com platform — such as which game categories are most visited and how long sessions last — so that we can measure platform performance and prioritize improvements. Data collected by performance cookies does not identify you individually.
• Functional Cookies: These cookies remember your choices and settings — such as language preference, preferred game category, and cashier defaults — to provide a more personalized experience on return visits.
• Analytics Cookies: 55com uses aggregated analytics data to understand traffic patterns, device and browser distributions among our Indonesian player base, and content engagement rates. Analytics data is processed in aggregate and not linked to individual Account records.
• Security Cookies: These cookies support our fraud detection and device fingerprinting systems by establishing a consistent device profile across your sessions. They are a core component of our account security infrastructure and are classified as strictly necessary for security purposes.

You may control non-essential cookies through your browser settings. Disabling performance, functional, or analytics cookies will not prevent you from using the 55com platform but may result in a reduced experience — for example, your session preferences may not be saved between visits. Disabling strictly necessary or security cookies will impair core platform functionality and is not recommended.

Data Retention

55com retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, to maintain compliance with regulatory obligations, or to resolve any outstanding disputes. The following retention periods apply as a general guide:

Upon expiry of the applicable retention period, your personal data will be securely deleted or irreversibly anonymized. Data that is anonymized — meaning it can no longer be linked to you as an individual — may be retained indefinitely for statistical and business intelligence purposes.

Data Security

55com implements a layered security architecture designed to protect your personal data from unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• Transport Encryption: All data transmitted between your device and the 55com platform is protected by 256-bit TLS/SSL encryption — the same standard applied by Indonesia's major banking institutions including BCA, Mandiri, and BNI.
• Data-at-Rest Encryption: Personal data stored in 55com's databases is encrypted at rest using AES-256 encryption. Financial data and identity documents receive additional access controls restricting visibility to authorized personnel only.
• Access Control: 55com operates a strict role-based access control (RBAC) policy. Staff members access only the minimum personal data required to perform their assigned function. Access to sensitive Member data is logged, monitored, and audited.
• Two-Factor Authentication: 55com's internal administrative systems require multi-factor authentication. Members are strongly encouraged to enable two-factor authentication on their own Accounts via the Account security settings.
• Penetration Testing & Vulnerability Scanning: The 55com platform undergoes regular third-party penetration testing and automated vulnerability scanning. Critical vulnerabilities are remediated within defined service-level timelines before the next deployment cycle.
• Incident Response: In the event of a data breach that is likely to result in a risk to your rights or freedoms, 55com will notify affected Members without undue delay and will take immediate steps to contain, investigate, and remediate the breach.

Your Data Rights

As a 55com Member, you hold the following rights in relation to your personal data. To exercise any of these rights, please contact our Data Protection Officer using the details in Clause 15. We will respond to all valid data rights requests within 30 calendar days of receipt, and within 7 calendar days for urgent requests related to security or identity theft.

• Right of Access: You may request a copy of the personal data 55com holds about you at any time. We will provide a structured, commonly readable summary of your data free of charge for the first request in any 12-month period.
• Right to Rectification: If any personal data held by 55com is inaccurate or incomplete, you have the right to request that it be corrected. Minor corrections such as address updates may be made directly through Account settings; corrections to identity or financial data require verification.
• Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent (for consent-based processing), or where you object to processing and no overriding legitimate interest exists. The right to erasure does not apply where retention is required by law — for example, AML record-keeping obligations mean that transaction and identity records must be retained for defined periods even after Account closure.
• Right to Restriction: You may request that 55com restrict processing of your personal data while the accuracy of data is contested, while an objection is pending, or where processing is unlawful but you prefer restriction over erasure.
• Right to Data Portability: For data that you provided directly to 55com and that is processed on the basis of contract or consent, you may request that we provide that data in a structured, machine-readable format that can be transmitted to another service provider.
• Right to Object: You may object at any time to processing of your personal data that is based on 55com's legitimate interests. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• Right to Withdraw Consent: Where 55com relies on your consent as the legal basis for processing — primarily for marketing communications — you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

If you are unsatisfied with 55com's response to a data rights request, you have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction. 55com is committed to resolving all privacy concerns through our internal process first; however, your right to escalate to a supervisory authority is unconditional.

Minors

The 55com platform is strictly intended for adults aged 21 years or older. 55com does not knowingly collect personal data from any person under the age of 21. All Accounts are subject to mandatory KYC age verification before withdrawal privileges are activated, using a valid Indonesian government-issued identity document such as a KTP, SIM, or passport.

If 55com becomes aware that personal data has been collected from a person under the age of 21 — whether through KYC review, a third-party report, or an Account security investigation — the relevant Account will be immediately suspended, all personal data associated with that Account will be deleted within 30 days except where retention is required to report the incident to relevant authorities, and all deposits will be returned to the verified payment source.

If you are a parent or guardian and believe that a minor in your care has created a 55com Account, please contact our support team immediately at [email protected] with the subject line "Minor Account Report." We will investigate and act on all such reports as a matter of highest priority.

International Data Transfers

55com operates as an international platform. Your personal data may be stored on servers located outside of Indonesia and may be accessed by 55com's operational teams or third-party service providers in other countries. Where personal data is transferred internationally, 55com ensures that appropriate safeguards are in place — including standard contractual clauses or equivalent data transfer mechanisms — to ensure that your data receives a level of protection consistent with this Privacy Policy regardless of its geographic location.

Specifically, data transfers to our game technology partners (including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft) are governed by data processing agreements that impose binding obligations on those providers regarding the security and confidentiality of any personal data they may access as part of their service delivery. Only anonymized or pseudonymized session identifiers are transmitted to game providers under normal operational circumstances.

Third-Party Services

The 55com platform integrates with third-party services including payment processors, game content delivery systems, and identity verification providers. Each of these third parties operates under its own privacy policy and data protection framework. 55com is not responsible for the privacy practices of third-party services accessed independently of the 55com platform.

55com selects third-party service providers through a due diligence process that evaluates their data security standards, regulatory standing, and contractual willingness to operate under terms consistent with this Privacy Policy. All third-party providers with access to personal data belonging to 55com Members are required to sign a Data Processing Agreement (DPA) with 55com before receiving any data access.

The following categories of third-party providers currently operate under DPAs with 55com:

• Indonesian local bank transfer gateway operators
• E-wallet integration providers (OVO, DANA, GoPay, ShopeePay, LinkAja network APIs)
• KYC and identity document verification platforms
• Game content studios and RNG certification bodies
• Cloud hosting and database infrastructure providers
• Fraud detection and AML screening services
• Customer support platform providers (live chat infrastructure)

Policy Amendments

55com reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, platform functionality, or data processing practices. When material changes are made — defined as changes that significantly affect your privacy rights or how your personal data is used — 55com will notify registered Members by email to the address on file and/or by a prominent notice on the platform at least 7 calendar days before the updated Policy takes effect.

Your continued use of the 55com platform after the effective date of an updated Privacy Policy constitutes your acceptance of the revised terms. The date at the top of this Policy marked "Last Updated" reflects the most recent revision. If you do not accept the revised Policy, you must cease using the platform and contact support to request Account closure before the effective date.

For non-material changes — such as corrections to typographical errors, clarifications that do not alter the substance of any data processing activity, or updates to contact details — 55com will update this page without prior notification, and the "Last Updated" date will be amended accordingly.

Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 55com handles your personal data, please contact us through the following channels. All privacy-related enquiries are handled by or escalated to our designated Data Protection Officer (DPO):

• Live Chat: Available directly on the 55com platform, 00:00–24:00 WIB, every day of the year including all Indonesian public holidays.
• Email: [email protected] — for general support enquiries. For formal privacy and data rights requests, please use the subject line "Data Privacy Request" to ensure your message is routed directly to the DPO team.
• Phone: +62 811 5500 5500 — available 00:00–24:00 WIB. For data rights requests, phone contact is best used for initial triage; we will ask you to follow up in writing for formal requests that require a documented response.

We commit to acknowledging all privacy-related communications within 48 hours of receipt and to providing a substantive written response within 30 calendar days. For requests that are complex or involve large volumes of data, we may extend the response period by a further 30 days, in which case we will notify you of the extension and the reason for it within the initial 30-day window.