Privacy Policy & Data Security

This Privacy Policy ("Policy") describes how diva11 ("we", "us", "our", the "Company") collects, uses, discloses, stores, and protects the personal information of users ("you", "User", "Player", "Member") of our online betting and gaming platform accessible at https://diva11.cam (the "Platform", "Website", "Service"). By registering an account or using the diva11 Service, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

This Privacy Policy should be read in conjunction with our Terms & Conditions and Responsible Gaming guidelines, which together form the complete legal framework governing your use of the diva11 Platform.

1. Information We Collect

1.1 Information You Provide Directly

When you register for a diva11 account, contact our customer support, or otherwise interact with our Service, you may provide the following categories of personal information:

• Account Registration Data: Full legal name, date of birth, gender, email address, mobile phone number, residential address (street, city, province, postal code), and username.
• Identity Verification Data (KYC): Government-issued identification documents such as Indonesian KTP (Kartu Tanda Penduduk), passport, or driver's license; proof of address documents (utility bills, bank statements); and photographs or scans of these documents.
• Financial Information: Bank account details (bank name, account number, account holder name), e-wallet account information (OVO, DANA, GoPay, ShopeePay, LinkAja account identifiers), credit/debit card details (card number, expiration date, CVV for payment processing only), and transaction history (deposits, withdrawals, bet placements, winnings).
• Communications: Content of messages, emails, or live chat conversations with our customer support team; feedback, complaints, or inquiries submitted through contact forms or support channels.
• Marketing Preferences: Your consent to receive promotional communications via email, SMS, push notifications, or other channels, and your preferences regarding the types of offers and content you wish to receive.

1.2 Information Collected Automatically

When you access and use the diva11 Platform, certain information is collected automatically through technical means, including:

• Device Information: Device type (smartphone, tablet, desktop), operating system (Android, iOS, Windows, macOS), browser type and version, screen resolution, and device identifiers (IP address, device ID).
• Usage Data: Pages viewed, features accessed, games played, bets placed, time spent on the Platform, navigation paths, clickstream data, and interaction patterns.
• Location Data: Approximate geographic location derived from your IP address to verify that you are accessing the Service from within Indonesia and to comply with jurisdictional restrictions. We do not collect precise GPS location data unless you explicitly grant permission through your device settings.
• Cookies and Similar Technologies: We use cookies, web beacons, local storage, and similar tracking technologies to recognize your device, remember your preferences, analyze usage patterns, deliver targeted content, and improve the overall user experience. For more details, see Section 6 (Cookies and Tracking Technologies).
• Log Files: Server logs that record technical information such as IP address, browser type, referring/exit pages, timestamps, and error messages for security, troubleshooting, and analytics purposes.

1.3 Information from Third Parties

diva11 may receive personal information about you from third-party sources, including:

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata), e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja), and international payment gateways (Visa, Mastercard) may share transaction details, account verification status, and fraud prevention data.
• Identity Verification Services: Third-party KYC and anti-fraud service providers may supply identity verification results, document authentication reports, and risk assessment scores.
• Affiliates and Marketing Partners: If you were referred to diva11 by an affiliate or marketing partner, we may receive information about the referral source, campaign identifiers, and your initial interaction with promotional materials.

2. How We Use Your Information

2.1 Primary Purposes

diva11 uses your personal information for the following core operational purposes:

• Account Management: Creating, maintaining, and managing your diva11 account; authenticating your identity upon login; processing account settings changes and preferences.
• Service Provision: Enabling you to place bets on sports events, play casino games, participate in togel (lottery) draws, access live dealer games, and use all other features of the diva11 Platform.
• Payment Processing: Facilitating deposits and withdrawals; processing transactions with Indonesian banks (BCA, BRI, BNI, Mandiri) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja); maintaining accurate financial records; detecting and preventing fraudulent transactions.
• Identity Verification (KYC): Verifying your age (21+ requirement), confirming your identity and residency in Indonesia, preventing underage gambling, detecting duplicate accounts, and complying with anti-money laundering (AML) and counter-terrorism financing (CTF) obligations.
• Customer Support: Responding to your inquiries, complaints, and technical support requests via live chat, email, or other communication channels; troubleshooting technical issues; resolving disputes.
• Security and Fraud Prevention: Monitoring for suspicious activity, unauthorized access, account takeover attempts, collusion, bonus abuse, and other forms of fraudulent or malicious behavior; implementing security measures to protect your account and the integrity of the Platform.
• Compliance with Legal Obligations: Meeting regulatory requirements imposed by licensing authorities; complying with Indonesian laws regarding online gambling, taxation, data protection, and consumer rights; responding to lawful requests from government authorities, law enforcement, or courts.

2.2 Secondary Purposes

With your consent (where required by law) or based on our legitimate interests, we may also use your personal information for:

• Marketing and Promotions: Sending you promotional offers, bonus notifications, newsletter content, event announcements, and personalized recommendations based on your betting and gaming preferences. You may opt out of marketing communications at any time by clicking the unsubscribe link in emails or adjusting your account preferences.
• Personalization: Customizing the Platform experience to match your interests, such as displaying relevant game recommendations, sports markets popular in Indonesia (BRI Liga 1, EPL, badminton tournaments), and tailored promotional offers.
• Analytics and Improvement: Analyzing user behavior, betting patterns, game popularity, and Platform performance to improve features, optimize user experience, develop new products, and enhance overall service quality.
• Research and Development: Conducting internal research on user demographics, preferences, and trends to inform business strategy and product development decisions.

3. Legal Basis for Processing (For Indonesian Users)

diva11 processes your personal data based on the following legal grounds under Indonesian privacy law and international data protection principles:

• Consent: You have provided explicit consent by registering an account, accepting this Privacy Policy, and opting in to specific data processing activities (e.g., marketing communications).
• Contractual Necessity: Processing is necessary to fulfill our obligations under the Terms & Conditions and to provide the services you have requested (account management, payment processing, game access).
• Legal Compliance: Processing is required to comply with Indonesian laws and regulations, including age verification, anti-money laundering obligations, tax reporting, and responses to lawful government requests.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security monitoring, Platform optimization, and customer support, provided these interests do not override your fundamental rights and freedoms.

4. How We Share Your Information

4.1 Third-Party Service Providers

diva11 shares your personal information with trusted third-party service providers who assist us in operating the Platform and delivering services to you. These providers are contractually obligated to handle your data securely and only for the purposes we specify. Categories of service providers include:

• Payment Processors: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata), e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja), and international payment gateways (Visa, Mastercard) that process deposits and withdrawals on your behalf.
• Identity Verification Providers: Third-party KYC and document verification services that authenticate your identity, age, and address to comply with regulatory requirements.
• Game and Software Providers: Licensed gaming software suppliers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft) that deliver casino games, live dealer games, slots, and crash games to the Platform.
• Cloud Hosting and Infrastructure: Data centers and cloud service providers that host the diva11 Platform, store data securely, and ensure high availability and performance.
• Customer Support Tools: Live chat platforms, ticketing systems, and CRM (customer relationship management) software that enable our support team to assist you efficiently.
• Analytics and Marketing Tools: Analytics platforms that help us understand user behavior, measure marketing campaign effectiveness, and optimize the Platform experience.
• Security and Fraud Prevention Services: Anti-fraud providers, security monitoring tools, and risk assessment platforms that protect the Platform and our users from malicious activity.

4.2 Legal and Regulatory Disclosure

diva11 may disclose your personal information to government authorities, law enforcement agencies, regulatory bodies, or courts when:

• Required by Indonesian law or regulation.
• Necessary to comply with a lawful court order, subpoena, or legal process.
• Requested by regulatory authorities overseeing online gambling or financial services in Indonesia or the jurisdiction where diva11 is licensed.
• Needed to protect the rights, property, or safety of diva11, our users, or the public (e.g., preventing fraud, investigating suspected criminal activity).

4.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, sale of assets, or bankruptcy, your personal information may be transferred to a successor entity as part of the business transaction. We will notify you via email and/or a prominent notice on the Platform before your data is transferred and becomes subject to a different privacy policy.

4.4 No Sale of Personal Data

diva11 does not sell, rent, or trade your personal information to third parties for their direct marketing purposes. Any data sharing is strictly for operational, legal, or security purposes as described in this Privacy Policy.

5. Data Retention

diva11 retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

Data Category	Retention Period	Rationale
Account Registration Data	Duration of account + 5 years after closure	Regulatory compliance, dispute resolution, legal defense
KYC Documents	Duration of account + 7 years after closure	Anti-money laundering and regulatory requirements
Transaction Records	7 years from transaction date	Financial auditing, tax compliance, fraud investigation
Betting and Gaming History	5 years from bet settlement date	Dispute resolution, game integrity monitoring, responsible gaming analysis
Customer Support Communications	3 years from last interaction	Service improvement, complaint resolution, legal defense
Marketing Consent Records	Until consent is withdrawn + 1 year	Compliance with marketing regulations, proof of consent
Device and Usage Logs	12 months from collection	Security monitoring, fraud detection, analytics

After the retention period expires, we will securely delete or anonymize your personal information in accordance with our data retention and deletion policies. Anonymized data (data that can no longer identify you) may be retained indefinitely for statistical, research, and analytical purposes.

6. Cookies and Tracking Technologies

6.1 What Are Cookies?

Cookies are small text files stored on your device (computer, smartphone, tablet) when you visit the diva11 Platform. Cookies allow us to recognize your device, remember your preferences, and provide a personalized user experience. We also use similar technologies such as web beacons (invisible pixels embedded in web pages or emails) and local storage (HTML5 storage).

6.2 Types of Cookies We Use

• Essential Cookies: Strictly necessary for the Platform to function properly. These cookies enable core features such as account login, session management, secure transactions, and access to member-only areas. Essential cookies cannot be disabled without impairing the functionality of the Platform.
• Performance and Analytics Cookies: Collect anonymous or aggregated information about how users interact with the Platform, including pages visited, time spent on pages, navigation paths, and error messages. This data helps us improve performance, identify technical issues, and optimize user experience.
• Functional Cookies: Remember your preferences (language, currency, display settings) and provide enhanced features such as personalized game recommendations and customized content based on your betting history.
• Marketing and Advertising Cookies: Track your activity across websites and platforms to deliver targeted advertisements and measure the effectiveness of marketing campaigns. These cookies may be set by diva11 or by third-party advertising partners with your consent.

6.3 Managing Cookies

Most web browsers allow you to control cookies through browser settings. You can configure your browser to refuse all cookies, accept only certain types of cookies, or delete cookies after each session. However, blocking or deleting essential cookies may impair your ability to use the diva11 Platform. For more information on managing cookies, consult your browser's help documentation.

7. Data Security

diva11 is committed to protecting your personal information from unauthorized access, disclosure, alteration, or destruction. We implement industry-standard technical and organizational security measures, including:

• 256-bit SSL Encryption: All data transmitted between your device and the diva11 Platform is encrypted using Secure Socket Layer (SSL) technology, the same encryption standard used by banks and financial institutions.
• Secure Data Storage: Personal information is stored on secure servers located in certified data centers with physical access controls, environmental monitoring, and redundancy systems to prevent data loss.
• Access Controls: Only authorized diva11 personnel and approved third-party service providers have access to your personal information, and only to the extent necessary to perform their job functions. Access is logged and monitored.
• Regular Security Audits: We conduct periodic security assessments, vulnerability scans, and penetration testing to identify and address potential security weaknesses.
• Employee Training: All diva11 employees and contractors with access to personal data are trained on data protection principles, security best practices, and confidentiality obligations.
• Incident Response Plan: In the unlikely event of a data breach, we have an incident response plan in place to promptly detect, contain, and remediate the breach, and to notify affected users and relevant authorities as required by law.

While we strive to protect your personal information, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials (username and password) and for notifying us immediately if you suspect unauthorized access to your account.

8. Your Privacy Rights

Under Indonesian privacy law and international data protection standards, you have the following rights with respect to your personal information:

• Right of Access: You may request a copy of the personal information we hold about you, including details about how your data is processed and the categories of recipients with whom it has been shared.
• Right to Rectification: If your personal information is inaccurate, incomplete, or outdated, you have the right to request correction or update of your data. You can update most account information directly through your diva11 account settings.
• Right to Deletion ("Right to Be Forgotten"): You may request deletion of your personal information in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, when you withdraw consent, or when the processing is unlawful. Note that we may be required to retain certain data for legal, regulatory, or contractual reasons even after you request deletion.
• Right to Restriction of Processing: You may request that we temporarily restrict processing of your personal information in certain situations, such as when you contest the accuracy of the data or object to processing based on legitimate interests.
• Right to Data Portability: Where technically feasible, you have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that data to another service provider.
• Right to Withdraw Consent: If we process your personal information based on your consent (e.g., for marketing communications), you may withdraw that consent at any time by adjusting your account preferences, clicking the unsubscribe link in promotional emails, or contacting our support team. Withdrawal of consent does not affect the lawfulness of processing that occurred prior to withdrawal.
• Right to Object: You have the right to object to processing of your personal information based on legitimate interests or for direct marketing purposes. Upon receiving an objection, we will cease processing unless we have compelling legitimate grounds that override your rights.
• Right to Lodge a Complaint: If you believe your privacy rights have been violated, you have the right to lodge a complaint with the relevant data protection authority in Indonesia or the jurisdiction where you reside.

8.1 Exercising Your Rights

To exercise any of the above rights, please contact us at [email protected] with the subject line "Privacy Rights Request". In your request, please specify which right you wish to exercise and provide sufficient information to verify your identity (such as your account username, registered email address, and date of birth). We will respond to your request within 30 days in accordance with applicable law. In some cases, we may need to request additional information to verify your identity and ensure the security of your personal data.

9. International Data Transfers

The diva11 Platform operates internationally, and your personal information may be transferred to, stored in, and processed in countries outside of Indonesia where our servers, service providers, or business partners are located. These countries may have data protection laws that differ from Indonesian law. When we transfer your personal information internationally, we take appropriate measures to ensure that your data receives an adequate level of protection, such as:

• Entering into data transfer agreements with service providers that include standard contractual clauses approved by data protection authorities.
• Conducting due diligence on the data protection practices and security measures of third-party service providers.
• Ensuring that service providers are certified under recognized privacy frameworks (e.g., ISO 27001, SOC 2).

10. Children's Privacy

The diva11 Platform is strictly intended for adults aged 21 years and older. We do not knowingly collect, use, or disclose personal information from individuals under the age of 21. If we become aware that we have inadvertently collected personal information from a person under 21, we will take immediate steps to delete that information and terminate the associated account. If you believe that a person under 21 has registered an account or provided personal information to diva11, please contact us immediately at [email protected].

11. Changes to This Privacy Policy

diva11 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or business operations. We will notify you of material changes by:

• Posting a prominent notice on the diva11 Platform homepage.
• Sending an email notification to the address registered on your account.
• Displaying an in-app notification upon your next login.

The "Last Updated" date at the top of this Privacy Policy indicates when the most recent changes were made. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your personal information. Continued use of the Platform after changes to this Privacy Policy constitutes your acceptance of the revised terms.

12. Contact Us

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

• Support Email: [email protected]
• Live Chat: Available 24/7 via the diva11 Platform (average response time under 60 seconds during WIB business hours)
• Subject Line for Privacy Inquiries: "Privacy Policy Question" or "Privacy Rights Request"

We are committed to resolving privacy concerns promptly and transparently. When you contact us, please provide your account username, registered email address, and a detailed description of your inquiry so that we can assist you effectively.