neo108 Privacy Policy

In this Privacy Policy, the following terms have the meanings set out below.

2.1 neo108 collects the following categories of Personal Data from Members and visitors:

2.1.1 Registration & Account Data

• Full legal name and date of birth;
• Email address and Indonesian mobile number;
• Username and encrypted password hash;
• Country of residence (Indonesia) and city (e.g., Jakarta, Surabaya, Bandung, Bali, Medan, Yogyakarta);
• Preferred currency (IDR / Rp) and language preference.

2.1.2 KYC & Verification Data

• Copies of government-issued photo ID (Indonesian KTP, passport, or SIM);
• Proof of address documents;
• Selfie photographs submitted as part of liveness checks;
• Proof of payment method ownership (e.g., bank statements from BCA, BRI, BNI, Mandiri, CIMB Niaga, or screenshots of e-wallet accounts including OVO, DANA, GoPay, ShopeePay, LinkAja).

2.1.3 Financial & Transaction Data

• Deposit and withdrawal history including amounts (IDR), dates, and payment channels;
• Bank account names and last-four digits (full account numbers are not stored);
• Bonus eligibility status and wagering activity records.

2.1.4 Gaming & Betting Activity Data

• Game session logs including titles played, bet amounts, win/loss outcomes, and session duration;
• Sportsbook betting history including markets, selections, odds, and stake amounts;
• Responsible gaming tool usage (e.g., deposit limit settings, self-exclusion requests, cooling-off periods).

2.1.5 Technical & Device Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, browser type and version;
• Session timestamps, page interaction logs, and referral URL;
• Cookie identifiers and similar tracking technologies (see Clause 6).

2.1.6 Communications Data

• Records of live chat conversations with customer support;
• Inbound emails to [email protected] and our written responses;
• Complaint and dispute records.

3.1 Directly from you: When you register an Account, complete our KYC process, make a deposit or withdrawal, contact customer support, participate in a promotion, or submit a responsible gaming request.

3.2 Automatically through your use of the Platform: Via cookies, server logs, and similar technologies that record how you interact with the Platform — including which pages you visit, how long you spend on each section, and what actions you take during a gaming session.

3.3 From Third-Party Service Providers: Our payment processors (including Indonesian bank transfer gateways and e-wallet platforms) may share transaction confirmation data with us. Fraud detection and KYC verification partners may provide identity verification results. Game studios may provide session-level activity data for game integrity and RTP audit purposes.

3.4 From publicly available sources: In limited circumstances related to fraud prevention or compliance, we may reference publicly available information to verify the accuracy of data you have provided.

4.1 neo108 processes your Personal Data for the following purposes, each supported by a lawful basis:

4.2 neo108 will not use your Personal Data for purposes materially different from those listed above without first notifying you and, where required, obtaining your consent.

5.1 neo108 does not sell your Personal Data. We share data only in the following limited circumstances:

5.1.1 Payment processors and banking partners: To facilitate deposits and withdrawals via Indonesian bank transfer networks (BCA, BRI, BNI, Mandiri, CIMB Niaga) and e-wallet platforms (OVO, DANA, GoPay, ShopeePay, LinkAja), we share the minimum necessary transaction and identity data required to complete your payment.

5.1.2 KYC and identity verification providers: We work with certified third-party KYC platforms to verify the authenticity of documents you submit. These providers process your KYC Data under strict data processing agreements and are prohibited from using your data for any other purpose.

5.1.3 Game studios and content providers: Studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive session-level data (bet amount, game outcome, session duration) to fulfil audit, RTP certification, and game integrity obligations. They do not receive your name, contact details, or financial account information.

5.1.4 Fraud prevention and cybersecurity providers: We share technical and behavioural data (IP address, device fingerprint, session patterns) with anti-fraud systems to protect both neo108 and its members from fraudulent activity.

5.1.5 Legal and regulatory authorities: neo108 will disclose Personal Data to law enforcement agencies, regulatory bodies, or courts where we are legally compelled to do so by a valid legal process. We will, where permitted by law, notify the affected Member of such a disclosure.

5.1.6 Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of neo108's assets, Member data may be transferred to the successor entity, subject to equivalent privacy protections.

6.1 neo108 uses cookies and similar technologies to operate the Platform effectively, personalise your experience, and support security monitoring. The following cookie categories are in use:

6.2 Most web browsers allow you to control cookies through their settings. Disabling functional or analytics cookies may affect your experience on the Platform but will not prevent you from accessing core gaming and betting features.

6.3 neo108 does not use third-party advertising cookies or retargeting pixels. We do not share cookie data with social media platforms or ad networks.

7.1 neo108 implements a comprehensive information security programme designed to protect your Personal Data against unauthorised access, disclosure, alteration, and destruction. Key security measures include:

• Encryption in transit: All data transmitted between your device and our servers is encrypted using 256-bit TLS 1.2 or higher protocols;
• Encryption at rest: Sensitive stored data, including KYC documents and financial records, is encrypted at rest using AES-256;
• Access controls: Internal access to Personal Data is restricted to authorised personnel on a strictly need-to-know basis, enforced via role-based access controls and multi-factor authentication;
• Payment tokenisation: Full bank account numbers and e-wallet credentials are never stored on neo108 servers. We store only the last four digits and account holder name for reference;
• Regular security audits: Our systems undergo periodic penetration testing and vulnerability assessments conducted by independent cybersecurity firms;
• Intrusion detection: Real-time monitoring systems detect and alert on anomalous access patterns, potential data breaches, and attempted intrusions.

7.2 In the event of a data breach that is likely to result in a high risk to your rights and freedoms, neo108 will notify affected Members without undue delay, providing details of the nature of the breach, the categories of data affected, and the steps we are taking to mitigate the impact.

7.3 While neo108 takes every reasonable measure to protect your data, no online platform can guarantee absolute security. Members also bear responsibility for protecting their own Account credentials and should never share their password, OTP, or PIN with any person, including individuals claiming to be neo108 staff.

8.1 neo108 retains your Personal Data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable legal, regulatory, or contractual obligations. The following retention schedule applies:

8.2 Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be linked to an identifiable individual. Anonymised and aggregated data may be retained indefinitely for statistical and analytical purposes.

9.1 As a neo108 Member, you hold the following rights in respect of your Personal Data. To exercise any of these rights, please contact us at [email protected] with your full name, registered email address, and a description of your request.

• Right of Access: You may request a copy of all Personal Data neo108 holds about you, along with information about how it is being used;
• Right to Rectification: If any of your Personal Data is inaccurate or incomplete, you have the right to request that we correct or update it promptly;
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purpose it was collected, subject to our legal retention obligations. Note that KYC and financial transaction data may be retained beyond Account closure as described in Clause 8;
• Right to Restrict Processing: You may request that we pause processing of your data in certain circumstances, such as while a dispute about its accuracy is resolved;
• Right to Data Portability: You may request a structured, machine-readable export of the Personal Data you have provided to us;
• Right to Object: You may object at any time to our processing of your data for marketing purposes. We will honour such objections immediately. You may also object to processing based on legitimate interests, though this right is subject to our overriding legitimate reasons;
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

9.2 neo108 will respond to all valid data rights requests within 14 business days. In complex cases, this may be extended by a further 14 business days, with written notification of the extension provided to the requesting Member.

9.3 neo108 will not discriminate against Members who exercise their privacy rights — your access to games, betting markets, and promotions will not be affected by a privacy rights request.

10.1 neo108 maintains strict age verification controls as part of our KYC programme. All Members are required to confirm their date of birth at registration and to provide documentary proof of age (via government-issued ID) before withdrawals are processed.

10.2 If neo108 discovers or has reason to believe that Personal Data has been collected from a person under 21 years of age, we will immediately suspend the associated Account, conduct a full review, and permanently delete all Personal Data collected from that individual upon confirmation of the age violation.

10.3 Parents and guardians who believe a minor may have accessed the Platform using falsified identity information are encouraged to contact us immediately at [email protected]. We will treat all such reports with the highest priority.

11.1 The neo108 platform integrates third-party services — including game engines from studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft — to deliver its games and live casino content. While these studios process limited session data, they operate their own privacy programmes and are contractually bound to handle data in accordance with our instructions.

11.2 The neo108 platform does not contain links to external third-party websites for purposes other than service delivery. This Privacy Policy applies solely to data processed by neo108 in connection with the Platform. neo108 is not responsible for the privacy practices of any external entity.

11.3 Where neo108 uses third-party analytics tools to measure Platform performance, those tools are configured to anonymise IP addresses and are prohibited by contract from cross-referencing neo108 analytics data with other data sources for advertising purposes.

12.1 neo108 primarily serves Members based in Indonesia. In delivering our Services, some of your Personal Data may be processed on servers or by service providers located outside Indonesia — for example, game studios or cybersecurity providers operating in other jurisdictions.

12.2 Where Personal Data is transferred internationally, neo108 ensures that appropriate safeguards are in place to protect the data to a standard equivalent to that described in this Policy. These safeguards include standard contractual clauses, data processing agreements, and, where applicable, transfers to jurisdictions that maintain recognised data protection standards.

12.3 Payment data relating to Indonesian bank accounts (BCA, BRI, BNI, Mandiri, CIMB Niaga) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja) is processed within payment gateways that comply with the applicable Indonesian payment industry standards and are subject to oversight by Bank Indonesia regulations.

13.1 neo108 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, new service features, or guidance from data protection authorities. The "Last Updated" date at the top of this page will be revised whenever a material change is made.

13.2 Where changes are material — such as a new category of data collection, a new sharing arrangement, or a change to your rights — neo108 will notify registered Members via a prominent in-platform notice and, where appropriate, by email to the address on your Account, with a minimum of 7 days' notice before the changes take effect.

13.3 Your continued use of the Platform after the effective date of any update to this Policy constitutes your acknowledgement of, and where required, consent to, the updated terms. If you do not agree with any update, you may request Account closure as described in our Terms & Conditions.

13.4 We encourage you to review this Privacy Policy periodically. Previous versions of this Policy are available on request by contacting [email protected].

14.1 If you have any questions, concerns, or requests regarding this Privacy Policy or how neo108 handles your Personal Data, please reach out through any of the following channels:

• Live Chat: Available 24 hours a day, 7 days a week via the chat widget on the Platform. Native Indonesian-speaking agents are available during WIB peak hours (09:00–23:00 WIB).
• Email: [email protected] — responses are typically provided within 24 hours on business days.

14.2 When submitting a privacy-related request, please include your full name, registered email address, and a clear description of your request or concern so that our team can handle it efficiently and accurately.

14.3 For responsible gaming enquiries, self-exclusion requests, or Account closure requests, please clearly state the nature of your request in your initial message. Our dedicated player welfare team prioritises these cases and will respond as quickly as possible.