panenz Privacy Policy

1. Definitions

Throughout this Privacy Policy the following terms carry these specific meanings:

• "panenz," "we," "us," "our" — the panenz online gaming platform and its authorized operators reachable at https://panenz.cam.
• "Personal Data" — any information that directly or indirectly identifies a living individual, including name, national identity number, email address, bank account details, IP address, and device identifiers.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, transfer, and deletion.
• "Data Subject" — the individual whose Personal Data is being processed, i.e., you as a registered player or website visitor.
• "KYC" (Know Your Customer) — the identity-verification process panenz performs before activating full account functionality, particularly for withdrawals.
• "Third-Party Processor" — any external service provider that processes Personal Data on our behalf under a data-processing agreement, such as payment processors and game providers.
• "Cookies" — small text files placed on your browser or device that help us remember preferences and analyze usage patterns.

2. Data We Collect

2.1 Data You Provide Directly

When you register an account, complete KYC verification, make a deposit or withdrawal, or contact our support team, you provide us with:

• Identity information: Full legal name, date of birth, gender, and nationality.
• Contact information: Residential address (including city — e.g., Jakarta, Surabaya, Bandung, Medan), email address, and mobile phone number.
• Government-issued identification: Indonesian KTP (Kartu Tanda Penduduk), SIM (driving licence), or passport number, together with scanned copies or photographs submitted during KYC.
• Financial information: Bank account numbers (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, Bank Permata), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja), and transaction histories.
• Selfie and biometric images: Photographs submitted for liveness checks during KYC. These are used solely for identity verification and are not stored as biometric templates beyond the verification event.
• Support communications: The content of live-chat transcripts, emails, and any attachments you send to our support team.

2.2 Data Collected Automatically

When you access the panenz website or use our gaming platform, we automatically collect:

• Device and technical data: IP address, browser type and version, operating system, screen resolution, device model, and mobile network.
• Usage data: Pages visited, session duration, clickstream data, search queries within our platform, game sessions played, bets placed, and features accessed.
• Geolocation data: Approximate location derived from your IP address, used to enforce jurisdiction eligibility checks. We do not collect precise GPS coordinates without explicit consent.
• Cookie and tracking data: Preference cookies, session tokens, analytics identifiers, and advertising attribution tags. See Section 6 for full detail.

2.3 Data from Third Parties

In limited circumstances we receive Personal Data from external sources:

• Identity-verification agencies: Third-party KYC providers may return verified identity scores, fraud flags, or sanctions-list matches.
• Payment processors: Transaction status confirmations and chargeback notifications from bank payment gateways.
• Fraud-detection partners: Risk scores and device-fingerprint signals used to protect your account from unauthorized access.
• Game providers: Aggregated session statistics from Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Pocket Games Soft used for game performance analysis.

3. How We Use Your Personal Data

panenz processes your Personal Data only for defined, legitimate purposes:

• Account creation and management: Creating and maintaining your panenz account, authenticating logins, and managing security settings.
• Identity verification (KYC): Fulfilling legal obligations to verify player identity, confirm minimum age of 21 years, and prevent fraud and money laundering.
• Processing payments: Executing deposits and withdrawals through Indonesian banks (BCA, BRI, BNI, Mandiri) and e-wallets, reconciling transactions, and investigating payment disputes.
• Providing gaming services: Delivering sports betting markets, live casino tables, slot games, togel (traditional lottery) products, and all other platform features.
• Customer support: Responding to queries, resolving disputes, and maintaining records of support interactions.
• Responsible gaming: Monitoring gaming behavior to identify signs of problem gambling, applying player-requested limits, and facilitating self-exclusion requests as described in our Responsible Gaming policy.
• Platform security: Detecting and preventing fraud, account takeovers, bonus abuse, collusion, and unauthorized bot activity.
• Legal and regulatory compliance: Maintaining records required by anti-money laundering (AML) regulations, responding to lawful requests from authorities, and retaining data for the periods specified in Section 7.
• Analytics and improvement: Aggregated and anonymized usage analytics to improve platform performance, game selection, and user experience.
• Marketing communications: Sending promotional emails and notifications about bonuses, new games, and special events — but only where you have given explicit consent. You may opt out at any time.

4. Legal Basis for Processing

panenz processes your Personal Data on the following legal bases:

• Contract performance: Processing necessary to provide the gaming services you have signed up for and to execute financial transactions on your behalf.
• Legal obligation: Processing required to comply with applicable laws, including KYC and AML regulations, data-retention requirements, and court orders.
• Legitimate interests: Processing for fraud prevention, platform security, and internal analytics where our interests do not override your fundamental rights and freedoms.
• Consent: Processing for direct marketing communications and non-essential cookies, where you have given freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time.

5. Data Sharing and Disclosure

5.1 Third-Party Service Providers

panenz shares your Personal Data with carefully selected third-party processors who act solely on our instructions and under binding data-processing agreements. These include:

• Payment gateway operators and Indonesian banks facilitating deposits and withdrawals.
• KYC and identity-verification providers.
• Fraud-detection and risk-scoring services.
• Cloud infrastructure and hosting providers operating data centres with ISO 27001 certification.
• Game software providers (Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, Pocket Games Soft) for game delivery and RNG certification purposes.
• Email and customer-communication platforms used to deliver support responses and marketing messages.

5.2 Regulatory and Law-Enforcement Disclosure

We may disclose Personal Data to government authorities, law enforcement agencies, or regulatory bodies when required by law, court order, or legally binding regulatory direction. We will notify you of such requests to the extent permitted by law.

5.3 Business Transfers

If panenz undergoes a merger, acquisition, or sale of assets, your Personal Data may be transferred to the acquiring entity as part of the transaction. You will be notified via a prominent notice on our website before your data becomes subject to any materially different privacy policy.

5.4 No Sale of Personal Data

panenz does not sell, rent, or trade your Personal Data to any third party for their own marketing or commercial purposes. Your information is shared only as described in this Section 5.

6. Cookies and Tracking Technologies

6.1 Types of Cookies We Use

• Essential cookies: Required for the website to function correctly — session tokens, authentication cookies, and security identifiers. These cannot be disabled.
• Preference cookies: Remember your language preference, display settings, and game history so that subsequent visits feel personalized.
• Analytics cookies: Collect aggregated data on page visits, session duration, and feature usage using tools such as server-side analytics. No personally identifiable data is sent to third-party analytics platforms without your consent.
• Marketing and attribution cookies: Track how you arrived at panenz (e.g., via a referral link) for affiliate-commission calculations. These are activated only with your consent.

6.2 Managing Your Cookie Preferences

You may control cookie settings through your browser's built-in privacy controls. Disabling non-essential cookies will not prevent you from using core platform features, but may reduce personalization and affect how accurately we can attribute promotions you are entitled to.

7. Data Retention

We retain your Personal Data only for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:

• Account and transaction data: Retained for a minimum of 5 years after account closure to satisfy AML and financial-regulation record-keeping requirements.
• KYC documents: Retained for 5 years after the end of the business relationship, or longer if required by a regulatory directive.
• Support communications: Retained for 3 years from the date of the interaction.
• Marketing consent records: Retained until you withdraw consent, plus an additional 2 years to demonstrate compliance.
• Server access logs: Retained for 12 months for security and fraud-investigation purposes.

When data is no longer required, it is securely deleted or irreversibly anonymized.

8. Security Measures

panenz implements a layered security architecture to protect your Personal Data against unauthorized access, disclosure, alteration, or destruction:

• Encryption in transit: All data transmitted between your browser and panenz servers is protected by TLS 1.2/1.3 (256-bit encryption). The website enforces HTTPS site-wide with HSTS headers.
• Encryption at rest: Sensitive fields — including bank account numbers, KTP numbers, and password hashes — are encrypted in the database using AES-256.
• Access controls: Personal Data is accessible only to panenz staff and authorized processors on a strict need-to-know basis. Access is logged and reviewed regularly.
• Two-factor authentication (2FA): Available to players and mandatory for internal administrative systems.
• Penetration testing: Our infrastructure undergoes regular third-party security assessments and vulnerability scanning.
• Incident response: We maintain a documented data-breach response plan. In the eve nt of a breach that is likely to result in a risk to your rights and freedoms, we will notify affected individuals within 72 hours of becoming aware of the incident.

9. Your Privacy Rights

As a Data Subject, you hold the following rights with respect to your Personal Data held by panenz. To exercise any of these rights, contact us at [email protected] with the subject line "Privacy Rights Request" and your registered account email address.

• Right of access: You may request a copy of the Personal Data we hold about you, together with information about how it is processed. We will respond within 30 days.
• Right to rectification: If any of your Personal Data is inaccurate or incomplete, you may request that we correct or update it without undue delay.
• Right to erasure ("right to be forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations described in Section 7. Note that data subject to AML regulations cannot be deleted during the mandatory retention window.
• Right to restriction of processing: You may ask us to suspend processing of your Personal Data in certain circumstances — for example, while you contest its accuracy or object to processing based on legitimate interests.
• Right to data portability: Where processing is based on your consent or contract performance and carried out by automated means, you may request your Personal Data in a structured, commonly used, machine-readable format (e.g., JSON or CSV).
• Right to object: You may object at any time to processing carried out on the basis of our legitimate interests, including profiling for direct marketing purposes. We will cease such processing unless we demonstrate compelling legitimate grounds that override your interests.
• 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 before the withdrawal.

We will respond to all valid rights requests within 30 calendar days. Where requests are complex or numerous, we may extend this period by a further 60 days and will inform you accordingly.

10. Minors and Age Policy

panenz services are strictly restricted to individuals who are at least 21 years of age. We do not knowingly collect, process, or retain Personal Data from anyone under 21. If you believe a minor has created a panenz account or submitted Personal Data to us, please notify us immediately at [email protected]. Upon confirmation, we will close the account, delete all associated Personal Data, and void any transactions.

We employ automated age-plausibility checks during registration and manual review during KYC to prevent underage access. Parents and guardians are encouraged to use reputable parental-control and web-filtering tools to block access to online gambling platforms on shared devices.

11. International Data Transfers

panenz operates infrastructure in multiple geographic regions to ensure platform performance and resilience. As a result, your Personal Data may be transferred to and processed in countries outside Indonesia. Wherever such transfers occur, panenz ensures that appropriate safeguards are in place, including:

• Standard contractual clauses approved by relevant data-protection authorities incorporated into contracts with all processors handling transferred data.
• Transfers only to processors operating in jurisdictions that maintain data-protection standards substantively equivalent to those applied in Indonesia.
• Encryption of data in transit and at rest as described in Section 8, regardless of where processing takes place.

12. Changes to This Privacy Policy

panenz may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or business operations. The "Last Updated" date at the top of this document will always reflect the most recent revision.

For material changes — those that significantly affect your rights or how we use your Personal Data — we will provide at least 14 days' advance notice via email to your registered address and a prominent banner on the website. Continued use of the panenz platform after the effective date of a revised policy constitutes your acceptance of the updated terms.

13. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way panenz handles your Personal Data, please reach out through any of the following channels:

• Email: [email protected] (please use the subject line "Privacy Inquiry" for faster routing)
• Live Chat: Available on every page of the Website, 24 hours a day, 7 days a week including Indonesian public holidays
• Response Time: Privacy-related inquiries are prioritized and typically receive a substantive response within 48 hours

We are committed to resolving privacy concerns fairly and transparently. If you are not satisfied with our response, you retain the right to escalate your complaint to the relevant data-protection or consumer-protection authority in your jurisdiction.

Effective Date: January 1, 2026

Last Updated: January 1, 2026

Version: 1.0