Privacy Policy — hdpbet

1 Definitions

Throughout this Privacy Policy, the following terms have the meanings assigned to them below:

• "Platform" — The hdpbet website at https://hdpbet.cam and any associated mobile or progressive-web applications operated by hdpbet.
• "We", "Us", "Our" — hdpbet and its parent entity, subsidiaries, affiliates, directors, officers, and authorized employees.
• "You", "User", "Data Subject" — Any natural person who accesses, registers on, or transacts through the Platform.
• "Personal Data" — Any information that identifies or can be used to identify you directly or indirectly, including your name, identification number, contact details, financial information, and device identifiers.
• "Processing" — Any operation performed on Personal Data, including collection, recording, storage, use, disclosure, erasure, or destruction.
• "Controller" — hdpbet, which determines the purposes and means of processing Personal Data collected through the Platform.
• "Processor" — Any third-party service provider that processes Personal Data on behalf of hdpbet under a contractual data-processing agreement.
• "KYC" — Know Your Customer — the identity verification process required before withdrawals and certain account activities are permitted.

2 Data We Collect

hdpbet collects Personal Data across the following categories. We collect only the data that is necessary for the purposes described in this Policy:

Identity & Contact Data

Financial & Payment Data

Behavioral & Activity Data

Technical Data

3 How We Collect Data

We collect Personal Data through the following channels:

• Direct Submission: Information you provide when registering an Account, completing KYC verification, making a deposit or withdrawal request, contacting our support team, or participating in a promotion.
• Automated Technologies: Data collected automatically when you visit the Platform, including cookies, web beacons, pixel tags, and server log files that record your IP address, browser fingerprint, and navigation behavior.
• Payment Processors: Confirmation and verification data returned by Indonesian banking networks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) when you initiate a transaction.
• Identity Verification Partners: Data returned by third-party KYC and anti-fraud service providers when we verify your identity documents.
• Analytics Providers: Aggregated and pseudonymized behavioral data collected by our analytics infrastructure to help us understand how the Platform is used and identify areas for improvement.

4 Purpose of Processing

hdpbet processes your Personal Data for the following specific purposes:

5 Legal Basis for Processing

hdpbet relies on the following legal bases when processing your Personal Data:

• Contractual Necessity: Processing required to perform the contract between you and hdpbet — including Account creation, transaction processing, and service delivery — is carried out on the basis that it is necessary to fulfill our contractual obligations to you.
• Legal Obligation: Processing required to comply with applicable legal requirements, including KYC identity verification, AML transaction monitoring, and responding to lawful requests from competent authorities.
• Legitimate Interests: Processing carried out in pursuit of hdpbet's legitimate business interests — including fraud prevention, platform security, and improving our services — where those interests are not overridden by your fundamental rights and freedoms.
• Consent: Where we rely on your consent as the legal basis (primarily for optional marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing. You may withdraw consent by updating your communication preferences in Account Settings or by contacting support.

6 Data Sharing

hdpbet does not sell, rent, or trade your Personal Data to third parties for their own marketing purposes. We share your data only with the categories of recipient described below, and only to the extent necessary for the specified purpose:

• Payment Service Providers: Indonesian banking networks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) receive transaction-related data to process deposits and withdrawals. These providers operate under their own applicable data-protection obligations.
• KYC & Identity Verification Partners: Third-party providers that verify identity documents and screen against sanctions and politically exposed person (PEP) lists. These providers act as data Processors under contractual data-processing agreements with hdpbet.
• Game Content Providers: Game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive session-level data necessary to deliver their games on the Platform. No personally identifiable financial information is shared with game studios.
• Analytics & Infrastructure Providers: Cloud-hosting and analytics vendors that process pseudonymized technical data to support platform operations and performance monitoring.
• Regulatory & Law Enforcement Authorities: Where required by law, court order, or a binding directive from a competent regulatory body, hdpbet may disclose your Personal Data without prior notice to you.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of hdpbet's assets, your Personal Data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

7 International Data Transfers

hdpbet operates infrastructure across multiple jurisdictions. As a result, your Personal Data may be transferred to and processed in countries outside Indonesia. Where such transfers occur, hdpbet takes appropriate safeguards to ensure that your data receives an equivalent level of protection to that which it would receive in Indonesia, including:

• Entering into data-processing agreements with recipients that incorporate internationally recognized standard contractual clauses.
• Transferring data only to jurisdictions that maintain adequate data-protection standards as assessed by hdpbet's compliance team.
• Applying technical and organizational security measures (including encryption in transit and at rest) to all cross-border data flows.

By using the Platform and submitting your Personal Data, you acknowledge and consent to such international transfers subject to the safeguards described above.

8 Data Retention

hdpbet retains your Personal Data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our standard retention schedule is as follows:

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymized so that it can no longer be associated with any identifiable individual. Where anonymization is not technically feasible, the data is placed under restricted access controls pending secure destruction.

9 Your Rights

As a User of the hdpbet Platform and a resident of Indonesia, you have the following rights in relation to your Personal Data. To exercise any of these rights, contact us at [email protected] with the subject line "Privacy Rights Request". We will respond within 30 calendar days of receiving a verifiable request.

• Right of Access: You may request a copy of the Personal Data we hold about you, together with information on how it is being processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete Personal Data. For certain data fields (name, date of birth), corrections require supporting documentation consistent with KYC requirements.
• Right to Erasure: You may request deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where processing is unlawful. This right is subject to overriding legal obligations — we cannot erase data we are required to retain under AML or KYC regulations.
• Right to Restrict Processing: You may request that we restrict the processing of your data in certain circumstances, such as while the accuracy of the data is being contested.
• Right to Data Portability: You may request a structured, machine-readable copy of the Personal Data you have provided to us, where processing is based on consent or contractual necessity.
• Right to Object: You may object to processing carried out on the basis of legitimate interests, including profiling for marketing purposes. You may also unsubscribe from marketing emails at any time via the unsubscribe link in any marketing message or through your Account Settings.
• 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 that occurred before withdrawal.

10 Cookies & Tracking Technologies

hdpbet uses cookies and similar tracking technologies on the Platform for the purposes described below. A cookie is a small text file placed on your device by our web server when you visit the Platform.

You can manage or withdraw your consent to non-essential cookies at any time through your browser settings or the cookie preference panel on the Platform. Please note that disabling strictly necessary cookies will impair the functionality of the Platform, including your ability to log in and place wagers.

11 Data Security

hdpbet implements a layered set of technical and organizational security measures designed to protect your Personal Data against unauthorized access, accidental loss, destruction, or disclosure. Key measures include:

• 256-Bit SSL/TLS Encryption: All data transmitted between your device and the Platform is encrypted using industry-standard TLS 1.3 protocols.
• Encryption at Rest: Sensitive Personal Data and financial records stored in our databases are encrypted at rest using AES-256 encryption.
• Mandatory Two-Factor Authentication (2FA): All registered Accounts are required to maintain 2FA, significantly reducing the risk of unauthorized access even if login credentials are compromised.
• Access Controls: Personal Data is accessible internally on a strict need-to-know basis. Staff access is governed by role-based access controls and reviewed quarterly.
• Intrusion Detection & Monitoring: Our infrastructure is monitored 24 hours a day, 7 days a week by automated intrusion-detection systems and a dedicated security team.
• Penetration Testing: The Platform undergoes regular independent security assessments and penetration testing to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: In the event of a data breach that is likely to result in a risk to your rights and freedoms, hdpbet will notify affected Users and the relevant authorities within the timeframe required by applicable law.

While hdpbet takes all reasonable steps to protect your Personal Data, no online platform can guarantee absolute security. You are responsible for keeping your Account credentials confidential and for notifying us immediately at [email protected] if you suspect any unauthorized access to your Account.

12 Minors

The hdpbet Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect Personal Data from individuals under the age of 21. During registration, all Users are required to confirm their date of birth, and KYC verification requires submission of a government-issued identity document. Any Account found to be registered by a person under 21 will be immediately closed and all associated data deleted, except where retention is required for legal or investigative purposes.

13 Changes to This Policy

hdpbet reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data-processing practices, applicable law, or Platform features. When we make material changes, we will notify registered Users via email to the address on record and/or via a prominent notice on the Platform at least 7 calendar days before the revised Policy takes effect.

The version of this Privacy Policy displayed on the Platform bearing the most recent effective date supersedes all prior versions. We encourage you to review this Policy periodically. Your continued use of the Platform following the effective date of any revised Policy constitutes your acknowledgment of and agreement to the updated terms.

A summary of material changes will be appended to the top of this page for a period of 90 days following each update, clearly indicating what has changed and why.

14 Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our data-processing practices, or if you wish to exercise any of your data-subject rights, please contact the hdpbet Data Privacy team through the following channels:

• Email: [email protected] — please use the subject line "Privacy Rights Request" or "Privacy Inquiry" as appropriate. We aim to respond within 2 to 6 hours for general inquiries and within 30 calendar days for formal rights requests.
• Live Chat: Available 24 hours a day, 7 days a week via the Platform. For privacy-related queries, our support agents can escalate your request to the Data Privacy team.
• WhatsApp: Available 08:00–23:00 WIB on Indonesian business days for general support inquiries.

All privacy-related communications must be submitted in English to ensure accurate handling by our Data Privacy team. We are committed to resolving all legitimate concerns promptly and transparently.