Privacy Policy

1. Introduction

fomo19 ("we", "us", "our") operates an online betting platform serving Indonesian players at https://fomo19.cam. We understand that privacy is fundamental to your trust in our services. This Privacy Policy governs the collection, processing, storage, and protection of personal information you provide when you create an account, deposit funds, place bets, or otherwise interact with our platform.

This policy applies to all users of fomo19 services, regardless of how you access the platform (desktop browser, mobile browser, or any other method). By creating an account or using our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your information as described herein.

If you do not agree with any part of this Privacy Policy, you must discontinue use of fomo19 services immediately. Your continued use of the platform after changes to this policy constitutes acceptance of those changes.

2. Information We Collect

fomo19 collects several categories of information to provide, maintain, and improve our services:

2.1 Information You Provide Directly

• Account Registration Data: Full legal name, date of birth, email address, mobile phone number, residential address, and username/password chosen during account creation
• Identity Verification Documents (KYC): Government-issued Indonesian National Identity Card (KTP), proof of address documents (utility bills, bank statements), and selfie photographs for identity confirmation
• Financial Information: Bank account details (bank name, account number, account holder name) for deposits and withdrawals, e-wallet account information (OVO, DANA, GoPay, ShopeePay, LinkAja), and transaction history
• Communication Data: Content of messages you send to customer support via live chat, email, WhatsApp, or in-app messaging
• Voluntary Information: Preferences, feedback, survey responses, and any other information you choose to provide

2.2 Information Collected Automatically

• Device Information: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers
• Usage Data: Pages visited, games played, bets placed, deposit and withdrawal amounts, session duration, click patterns, and timestamps of activities
• Location Data: Approximate geographic location derived from IP address to verify you are accessing from Indonesia
• Cookies and Similar Technologies: Data collected through cookies, web beacons, and similar tracking technologies (see Section 6 for details)

2.3 Information from Third-Party Sources

• Payment Processors: Transaction confirmation data from BCA, BRI, BNI, Mandiri, and e-wallet providers
• Identity Verification Services: Information from third-party identity verification and fraud prevention services used to validate your KTP and other documents
• Game Providers: Betting history and gameplay data from third-party game providers like Pragmatic Play, Evolution Gaming, and others

3. How We Use Your Information

fomo19 uses the collected information for the following legitimate business purposes:

3.1 Service Provision and Account Management

• Create and maintain your fomo19 account
• Process account registration and KYC verification
• Authenticate your identity and prevent unauthorized access
• Enable you to deposit funds, place bets, and withdraw winnings
• Manage your account balance and transaction history
• Provide customer support and respond to your inquiries

3.2 Legal and Regulatory Compliance

• Verify you are at least 21 years of age and meet eligibility requirements
• Comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations
• Detect and prevent fraud, money laundering, and other illegal activities
• Maintain required records for regulatory audits and legal purposes
• Enforce our Terms & Conditions and other policies
• Respond to legal requests from law enforcement or regulatory authorities

3.3 Service Improvement and Personalization

• Analyze usage patterns to improve platform functionality and user experience
• Personalize content, game recommendations, and promotional offers based on your preferences
• Conduct research and development to enhance our services
• Test new features and optimize platform performance

3.4 Marketing and Communications

• Send promotional emails about bonuses, new games, and special offers (with your consent)
• Deliver transactional notifications about deposits, withdrawals, and account activity
• Provide important service announcements and policy updates
• Conduct customer satisfaction surveys and gather feedback

3.5 Responsible Gaming

• Monitor betting patterns to identify potential problem gambling behavior
• Enforce deposit limits, loss limits, and self-exclusion requests
• Provide access to responsible gaming tools and resources
• Intervene when we detect signs of gambling-related harm

4. Data Sharing and Third Parties

fomo19 does not sell, rent, or trade your personal information to third parties for marketing purposes. However, we may share your data with the following categories of recipients for legitimate business purposes:

4.1 Service Providers

• Payment Processors: BCA, BRI, BNI, Mandiri, and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to process deposits and withdrawals
• Game Providers: Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, and other game studios to deliver gaming content
• Identity Verification Services: Third-party KYC and fraud prevention providers to verify your identity and detect suspicious activity
• Customer Support Tools: Live chat platforms, email services, and CRM systems used to provide customer support
• Analytics Providers: Services that help us understand platform usage and improve user experience

4.2 Legal and Regulatory Authorities

We may disclose your information to law enforcement, regulatory bodies, or courts when required by law, in response to valid legal requests, or to protect our legal rights and those of our users. This includes compliance with anti-money laundering investigations, tax authorities, and other governmental agencies.

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the acquiring entity. You will be notified via email and on-site notice of any such change in ownership or control of your personal information.

4.4 With Your Consent

We may share your information with other third parties when you provide explicit consent for us to do so.

4.5 Data Sharing Safeguards

All third parties with whom we share data are contractually obligated to maintain confidentiality, use the data only for specified purposes, and implement appropriate security measures. We conduct due diligence on all service providers to ensure they meet our privacy and security standards.

5. Data Security Measures

Protecting your personal information is a top priority at fomo19. We implement comprehensive technical, organizational, and physical security measures to safeguard your data:

5.1 Technical Security

• Encryption: All data transmission between your device and our servers is protected with 256-bit SSL (Secure Socket Layer) encryption, the same technology used by banks
• Data Encryption at Rest: Sensitive data stored in our databases is encrypted using industry-standard encryption algorithms
• Secure Authentication: Account access requires secure username/password authentication, with password complexity requirements and optional two-factor authentication (2FA)
• Firewalls and Intrusion Detection: Multi-layered firewall protection and real-time intrusion detection systems monitor for unauthorized access attempts
• Regular Security Audits: Independent security firms conduct penetration testing and vulnerability assessments quarterly

5.2 Organizational Security

• Access Controls: Strict role-based access controls ensure only authorized personnel can access personal data on a need-to-know basis
• Employee Training: All staff receive regular training on data protection, privacy regulations, and security best practices
• Confidentiality Agreements: Employees and contractors sign legally binding confidentiality agreements
• Incident Response Plan: Comprehensive procedures for detecting, responding to, and reporting data breaches

5.3 Physical Security

• Servers are housed in secure data centers with 24/7 surveillance, biometric access controls, and environmental monitoring
• Redundant backup systems ensure data availability and disaster recovery capability

5.4 Your Role in Security

While we implement robust security measures, you also play a critical role in protecting your account. Never share your password with anyone, use a strong unique password, log out after each session on shared devices, and contact us immediately if you suspect unauthorized access to your account.

6. Cookies and Tracking Technologies

fomo19 uses cookies, web beacons, and similar technologies to enhance user experience, analyze platform usage, and deliver personalized content.

6.1 What Are Cookies?

Cookies are small text files stored on your device when you visit our website. They help us recognize your browser, remember your preferences, and provide a seamless experience across sessions.

6.2 Types of Cookies We Use

• Essential Cookies: Required for core platform functionality including login authentication, session management, and security features. These cannot be disabled without impairing site functionality.
• Performance Cookies: Collect anonymous data about how visitors use our site, which pages are most popular, and if users encounter errors. This helps us improve platform performance.
• Functionality Cookies: Remember your preferences (language, currency display, game favorites) to provide a personalized experience.
• Advertising Cookies: Track your activity across websites to deliver targeted promotional content. These are only used with your consent.

6.3 Managing Cookies

You can control cookie preferences through your browser settings. Most browsers allow you to refuse cookies or delete existing cookies. However, disabling essential cookies may limit your ability to use certain features of the fomo19 platform. Consult your browser's help documentation for specific instructions on cookie management.

7. Your Privacy Rights

Under international data protection principles (including GDPR standards), 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. We will provide this in a commonly used electronic format within 30 days of your request.

7.2 Right to Rectification

You can update or correct inaccurate personal information directly in your account settings or by contacting customer support. We will process corrections within 7 business days.

7.3 Right to Erasure (Right to be Forgotten)

You may request deletion of your personal information when it is no longer necessary for the purposes for which it was collected, or if you withdraw consent. However, we may retain certain data if required by law or for legitimate business purposes (fraud prevention, regulatory compliance, dispute resolution).

7.4 Right to Restrict Processing

You can request restriction of processing your personal data in certain circumstances, such as when you contest the accuracy of the data or object to processing.

7.5 Right to Data Portability

You have the right to receive your personal data in a structured, machine-readable format and transmit it to another service provider.

7.6 Right to Object

You can object to processing of your personal data for direct marketing purposes at any time. We will honor such requests immediately.

7.7 Right to Withdraw Consent

Where processing is based on consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing conducted before withdrawal.

7.8 Exercising Your Rights

To exercise any of these rights, contact our privacy team at [email protected] with "Privacy Rights Request" in the subject line. We will respond within 30 days and may request identity verification to prevent unauthorized access to your data.

8. Data Retention and Deletion

fomo19 retains personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements.

8.1 Active Accounts

While your account remains active, we retain all associated personal information to provide ongoing services.

8.2 Closed Accounts

When you close your account voluntarily, we retain your information for a minimum of 5 years to comply with financial regulations and tax requirements. After this period, personal data is anonymized or deleted unless retention is required for legal proceedings.

8.3 Regulatory Requirements

Certain data (transaction records, KYC documents, communication logs) must be retained for regulatory compliance purposes for periods ranging from 5 to 10 years depending on the data type and applicable law.

8.4 Deletion Process

When data is deleted, it is permanently removed from our active systems and backups within 90 days. Deletion is irreversible.

9. International Data Transfers

fomo19 operates internationally and may transfer your personal information to servers located outside Indonesia for processing and storage. When we transfer data internationally, we ensure appropriate safeguards are in place:

• We only transfer data to jurisdictions with adequate data protection laws or entities that have committed to GDPR-equivalent standards
• We use standard contractual clauses approved by data protection authorities
• We implement technical and organizational measures to protect data during transfer
• Third-party processors in other countries are contractually bound to the same privacy standards as fomo19

By using fomo19 services, you consent to the transfer of your information to countries outside Indonesia under these safeguards.

10. Children's Privacy

fomo19 services are strictly for adults aged 21 years or older. We do not knowingly collect, use, or store personal information from individuals under 21 years of age. Our registration process requires date of birth verification, and we conduct KYC checks to ensure age compliance.

If we discover that we have inadvertently collected information from a person under 21, we will immediately delete that information and permanently close the associated account. Parents or guardians who believe their child has provided information to fomo19 should contact us immediately at [email protected].

Underage gambling is illegal and we take violations extremely seriously. Any attempt to use fomo19 services while underage will result in account termination and potential reporting to authorities.

11. Changes to This Policy

fomo19 reserves the right to update this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or business operations. When we make material changes, we will:

• Update the "Last Updated" date at the top of this page
• Notify you via email to your registered email address
• Display a prominent notice on the fomo19 platform
• Provide a summary of significant changes

Your continued use of fomo19 services after changes are posted constitutes acceptance of the updated Privacy Policy. If you do not agree with the changes, you must discontinue use and may request account closure. We encourage you to review this policy periodically to stay informed about how we protect your information.

12. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Email: [email protected] (for privacy-related inquiries, use subject line "Privacy Inquiry")
• Data Protection Officer: [email protected]
• Live Chat: Available 24/7 on our website
• Response Time: We aim to respond to all privacy inquiries within 48 hours, with full resolution within 30 days

For formal complaints or unresolved privacy concerns, you may contact the relevant data protection authority in your jurisdiction, though we encourage you to contact us first so we can address your concerns directly.