Privacy Policy

1. Introduction

cuan54 ("we", "us", "our", "Company") operates the online betting and gaming platform accessible at https://cuan54.cam. We are committed to protecting the personal data of all users ("you", "Player", "User") who access or use our Platform. This Privacy Policy ("Policy") sets out the principles and practices that govern our collection, use, storage, disclosure, and protection of your personal information.

This Policy applies to all personal data processed in connection with your use of the cuan54 Platform, including account registration, deposits and withdrawals, customer support interactions, promotional activities, and your general browsing activity on our website. By creating an account or continuing to use the cuan54 Platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein.

This Policy should be read in conjunction with our Terms & Conditions, which govern your overall use of the Platform. If you have any concerns about how your data is handled, please contact us using the details provided in Section 16.

2. Definitions

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, date of birth, email address, phone number, financial information, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" means cuan54, which determines the purposes and means of processing your Personal Data.
• "Data Processor" means a third party that processes Personal Data on behalf of cuan54, such as payment processors and KYC verification providers.
• "Cookies" means small text files placed on your device by the Platform that collect browsing and usage information.
• "KYC" means Know Your Customer — the identity verification process required to comply with anti-money laundering (AML) obligations and to confirm that Players meet the eligibility criteria set out in our Terms & Conditions.

3. Data We Collect

cuan54 collects the following categories of personal data in the course of operating our Platform:

3.1 Identity and Contact Information

• Full legal name as it appears on your government-issued identification.
• Date of birth (used for age verification — all Players must be 21 or older).
• Indonesian National Identity Card (KTP) number or passport number.
• Residential address in Indonesia (city, province, postal code).
• Email address and mobile phone number.

3.2 Financial Information

• Bank account details for deposit and withdrawal processing via BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, or Bank Danamon.
• E-wallet identifiers for OVO, DANA, GoPay, ShopeePay, and LinkAja transactions.
• Transaction history including deposit amounts, withdrawal amounts, dates, and reference numbers, all denominated in Indonesian Rupiah (IDR / Rp).

3.3 Account and Gaming Activity

• Username, account ID, and login credentials (passwords stored in hashed form only).
• Betting history, game session data, wager amounts, and outcomes.
• Bonus and promotion utilization records.
• Responsible gaming settings, including any deposit limits or self-exclusion elections.

3.4 Technical and Device Data

• IP address and geolocation data (used to verify that access originates from an eligible jurisdiction).
• Device type, operating system, browser type and version.
• Session duration, pages visited, click-path data, and referral source.
• Cookie identifiers and similar tracking technologies as described in Section 8.

3.5 Communications Data

• Records of customer support interactions via live chat, email, or any other communication channel.
• Survey responses, feedback submissions, and promotional opt-in preferences.

4. How We Collect Your Data

cuan54 collects personal data through the following means:

• Direct submission: Information you provide when registering an account, completing KYC verification, making a transaction, or contacting our support team.
• Automated technologies: Cookies, web beacons, server logs, and analytics scripts that record your interactions with the Platform.
• Third-party providers: Identity verification agencies, payment processors, fraud prevention services, and analytics platforms that share data with us in connection with your use of the Platform.
• Publicly available sources: In limited circumstances, we may supplement your profile with information from public databases to verify your identity or address.

5. How We Use Your Personal Data

cuan54 uses your personal data for the following purposes:

Purpose	Details
Account Management	Creating, maintaining, and securing your account; processing login and authentication.
Identity Verification (KYC)	Confirming your age (21+), identity, and residency in Indonesia as required by our Terms & Conditions.
Payment Processing	Executing deposits and withdrawals via Indonesian banks and e-wallets; maintaining transaction records.
Fraud and AML Prevention	Detecting, investigating, and preventing fraudulent activity, money laundering, and other financial crimes.
Platform Improvement	Analyzing usage patterns to improve game offerings, interface design, and overall user experience.
Marketing & Promotions	Sending bonus offers, seasonal promotions (e.g., Idul Fitri, Ramadhan, Independence Day), and newsletters where you have opted in.
Customer Support	Responding to inquiries, resolving disputes, and maintaining communication records.
Responsible Gaming	Monitoring gaming activity to identify potential problem gambling behaviors and administering your chosen responsible gaming settings.
Legal Compliance	Fulfilling legal obligations including record-keeping, responding to regulatory requests, and enforcing our Terms & Conditions.

6. Legal Basis for Processing

cuan54 processes your personal data on the following legal grounds:

• Contractual necessity: Processing required to fulfill our obligations under the Terms & Conditions, including account management, payment processing, and KYC verification.
• Legitimate interests: Processing necessary for our legitimate business interests, such as fraud prevention, platform security, and product improvement, where these interests are not overridden by your privacy rights.
• Consent: Processing of data for direct marketing purposes where you have explicitly opted in to receive such communications. You may withdraw this consent at any time by contacting our support team.
• Legal obligation: Processing required to comply with applicable laws and regulatory requirements, including anti-money laundering (AML) obligations.

7. Data Sharing and Disclosure

cuan54 does not sell, rent, or trade your personal data to unaffiliated third parties for their own marketing purposes. We may share your data in the following limited circumstances:

7.1 Service Providers

We engage trusted third-party service providers who act as Data Processors on our behalf, including payment gateways, KYC verification providers, fraud detection services, cloud infrastructure providers, and customer support platforms. These providers are contractually obligated to process your data only as instructed by cuan54 and to maintain appropriate security standards.

7.2 Legal and Regulatory Disclosure

We may disclose your personal data to law enforcement agencies, regulato ry authorities, or other governmental bodies where we are legally required or compelled to do so by a valid legal process, court order, or applicable law.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of cuan54's business assets, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify you of any such transfer and any resulting changes to this Privacy Policy via a prominent notice on the Platform or by email to your registered address.

7.4 Affiliated Companies

We may share your data with companies within the cuan54 group of companies for internal administrative purposes, fraud prevention, and the provision of consistent services across platforms. All intra-group transfers are subject to the same data protection standards as set out in this Policy.

8. Cookies and Tracking Technologies

cuan54 uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain session security, and gather analytics data that helps us improve our services. The following categories of cookies are in use:

• Strictly Necessary Cookies: Essential for the Platform to function correctly, including session management, authentication, and security tokens. These cookies cannot be disabled without impacting Platform functionality.
• Performance and Analytics Cookies: Used to collect anonymized data about how visitors navigate the Platform, including pages visited, time on page, and error events. This data helps us identify and resolve technical issues and improve the user experience.
• Functional Cookies: Enable the Platform to remember your preferences, such as your preferred language setting, display options, and responsible gaming configurations.
• Marketing and Targeting Cookies: Used to deliver relevant promotional content and to measure the effectiveness of our marketing campaigns. These cookies are only placed with your consent.

You may manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform. For strictly necessary cookies, no consent is required as they are essential to service delivery.

9. Data Retention

cuan54 retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, to comply with our legal obligations, to resolve disputes, and to enforce our agreements. The following retention guidelines apply:

• Active Account Data: Retained for the duration of your account's active status and for a period of at least five (5) years following account closure, in accordance with applicable AML and financial record-keeping requirements.
• Transaction Records: Financial transaction data is retained for a minimum of five (5) years from the date of each transaction.
• KYC Documentation: Identity verification documents are retained for a minimum of five (5) years from the date of submission or account closure, whichever is later.
• Customer Support Records: Communication records are retained for three (3) years from the date of the most recent interaction.
• Marketing Data: Where you have opted in to marketing communications, your marketing preferences are retained until you withdraw your consent or request erasure.
• Technical and Usage Data: Anonymized analytics data may be retained indefinitely for aggregate statistical analysis; individually identifiable technical data is retained for up to twelve (12) months.

Once the applicable retention period expires, your personal data is securely deleted or anonymized in accordance with our internal data disposal procedures.

10. Data Security

cuan54 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security infrastructure includes:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using industry-standard Transport Layer Security (TLS) protocols.
• Hashed Password Storage: Passwords are never stored in plain text. We use a one-way cryptographic hashing algorithm with salting to store all account passwords securely.
• Two-Factor Authentication (2FA): Players are encouraged to enable 2FA on their accounts for an additional layer of access security.
• Access Controls: Access to personal data within cuan54 is restricted on a strict need-to-know basis. Staff with access to personal data undergo regular security training and are bound by confidentiality obligations.
• Penetration Testing: Our Platform undergoes regular third-party security audits and penetration tests to identify and remediate vulnerabilities.
• Incident Response: We maintain a documented data breach response plan. In the event of a breach affecting your personal data, we will notify you and any applicable regulatory authority in accordance with our obligations and within the timeframes required by law.

11. Your Privacy Rights

As a user of the cuan54 Platform, you have the following rights with respect to your personal data. To exercise any of these rights, please contact our Data Protection team using the details provided in Section 16.

• Right of Access: You have the right to request a copy of the personal data we hold about you, along with information about how it is processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: In certain circumstances, you have the right to request that we delete your personal data. Please note that this right is subject to limitations where we are required to retain data for legal or regulatory compliance purposes.
• Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to our processing activities.
• Right to Data Portability: Where processing is based on your consent or contractual necessity and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time, with no need to provide justification.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

We will respond to all verified data rights requests within 30 calendar days of receipt. In complex cases, we may extend this period by a further 60 days, in which case we will notify you of the extension and the reasons for it.

12. Children's Privacy

The cuan54 Platform is strictly intended for adults. We do not knowingly collect personal data from persons under the age of 21. By registering an account, you represent and warrant that you are at least 21 years of age. If we become aware that we have collected personal data from a person under 21, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that a person under 21 in your care has registered an account or provided personal data to cuan54, please contact our support team immediately at [email protected] so that we can take appropriate action.

13. Third-Party Links and Services

The cuan54 Platform may contain references to third-party game studios (such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft) and payment service providers. While these partners are carefully vetted, cuan54 is not responsible for the privacy practices or content of third-party services. We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of the Platform.

14. International Data Transfers

cuan54 operates in an international environment, and your personal data may be transferred to and processed in countries other than Indonesia. Where such transfers occur, we ensure that appropriate safeguards are in place to protect your data to a standard equivalent to that described in this Policy. These safeguards may include contractual clauses, data processing agreements, and adherence to recognized international data transfer frameworks.

15. Changes to This Privacy Policy

cuan54 reserves the right to amend this Privacy Policy at any time. Where changes are material — for example, where we introduce a new purpose for processing your data or change the categories of third parties with whom your data is shared — we will provide advance notice by posting a prominent notification on the Platform or by sending an email to your registered address at least 14 days before the changes take effect.

Non-material changes, such as clarifications of existing practices or corrections of typographical errors, take effect immediately upon publication. The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. We encourage you to review this Policy periodically to stay informed about how we protect your data.

16. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact our Data Protection team:

We take all privacy inquiries seriously and will acknowledge your request within 48 hours. For formal data rights requests (access, erasure, rectification, portability), please include your registered email address and account ID to help us process your request efficiently.