Privacy Policy

1 Overview & Scope

This Privacy Policy applies to all personal data processed by tuna55 in connection with the operation of its online betting platform, including data collected through the tuna55 website (https://tuna55.cam), any associated mobile interfaces, customer support channels, email communications, and marketing activities.

This Policy covers all individuals who:

• Register or hold a tuna55 Member Account;
• Visit the tuna55 website without registering;
• Contact tuna55 customer support via live chat, email, or any other channel;
• Participate in tuna55 promotions, surveys, or competitions; or
• Otherwise interact with tuna55 services in any capacity.

This Policy does not cover the data practices of third-party websites, payment processors, game studios, or other external providers whose services are accessed through or in connection with the tuna55 platform. Each such provider operates under its own privacy policy, and we encourage you to review those policies independently.

2 Definitions

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

• "Personal Data" — any information relating to an identified or identifiable natural person ("data subject"), including but not limited to name, identification number, location data, online identifier, or factors specific to that person's identity.
• "Processing" — any operation performed on personal data, including collection, recording, storage, adaptation, retrieval, consultation, use, disclosure, transmission, restriction, erasure, or destruction.
• "Data Controller" — tuna55, which determines the purposes and means of processing personal data collected through the platform.
• "Data Processor" — any third party that processes personal data on behalf of tuna55, including payment processors, identity verification providers, and cloud hosting providers.
• "Member" — an individual who has completed the tuna55 account registration process and holds an active or inactive Account on the platform.
• "Cookies" — small text files placed on a user's device by the tuna55 website to store preferences, session data, and usage analytics.
• "KYC" — Know Your Customer; the identity and age verification process required before certain platform features (particularly withdrawals) are enabled.
• "Sensitive Data" — a specific category of personal data that warrants enhanced protection, including identity document details, financial account information, and data relating to a Member's betting and gaming activity.

3 Data We Collect

tuna55 collects the following categories of personal data from Members and platform visitors:

3.1 Registration Data

• Full legal name (as it appears on your national identity document)
• Date of birth
• Indonesian mobile phone number
• Email address
• Residential address in Indonesia
• Chosen username and encrypted password

3.2 Identity Verification (KYC) Data

• Scanned copy or photograph of your Indonesian national identity card (KTP), passport, or driver's license
• Proof of address documentation (utility bill, bank statement, or similar)
• Proof of payment method (bank account details registered under your name)
• Source of funds documentation where required for high-volume accounts
• Facial biometric data (selfie photograph) for identity matching where applicable

3.3 Financial & Transaction Data

• Bank account details (account name, account number, bank name — e.g., BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata, BSI)
• E-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja account details)
• Deposit and withdrawal history including amounts, timestamps, and payment method used
• Account balance and transaction ledger data

3.4 Betting & Gaming Activity Data

• Bet placement history (market, stake amount, odds, outcome, game type)
• Bonus and promotional offer usage records
• Session duration, login frequency, and platform engagement patterns
• Game type preferences (sports betting, live casino, slot games, togel lottery markets, etc.)

3.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Unique device identifiers
• Session tokens and authentication logs

3.6 Communication Data

• Live chat transcripts and email correspondence with tuna55 customer support
• Feedback, complaint, and dispute records
• Responses to surveys, promotions, or marketing communications

4 How We Collect Data

tuna55 collects personal data through the following methods:

• Directly from you: when you register an Account, complete KYC verification, make a deposit or withdrawal, place a bet, contact customer support, or participate in a promotion.
• Automatically: through cookies, web beacons, server logs, and other trackin g technologies when you visit or interact with the tuna55 platform.
• From third-party service providers: including identity verification agencies, payment processors, fraud detection services, and analytics providers who share data with us in connection with the services they provide on our behalf.
• From public sources: where permitted by applicable law, we may supplement the data you provide with information from publicly available sources for fraud prevention or KYC compliance purposes.

5 Purposes of Processing

tuna55 processes your personal data only for specified, explicit, and legitimate purposes. The table below summarizes our primary processing activities:

6 Legal Basis for Processing

tuna55 processes personal data on the following legal bases:

• Contractual necessity: Processing required to fulfill our obligations to you as a Member — including account management, payment processing, and game service delivery — is carried out on the basis that it is necessary for the performance of our contract with you.
• Legal obligation: Processing required to comply with applicable legal obligations, including KYC identity verification, anti-money laundering (AML) checks, and responses to lawful requests from regulatory or law enforcement authorities.
• Legitimate interests: Processing carried out for fraud prevention, security monitoring, platform optimization, and responsible gaming protection, where these interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing carried out for optional purposes — such as marketing communications, optional analytics, and non-essential cookies — is based on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without penalty by contacting customer support or adjusting your account communication preferences.

7 Data Sharing & Disclosure

tuna55 does not sell your personal data to any third party for commercial marketing purposes. We share personal data only in the following circumstances and with the following categories of recipients:

7.1 Service Providers (Data Processors)

We share data with trusted third-party service providers who process data solely on our behalf and under our documented instructions, including:

• Payment processors: Indonesian banking partners (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata, BSI) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) for the purpose of processing deposits and withdrawals.
• Identity verification providers: KYC and AML compliance specialists who verify Member identity documents and screen against sanctions lists.
• Game content providers: Third-party game studios (including Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Pocket Games Soft, and Spribe) receive session tokens and anonymized player identifiers to deliver game content. These providers do not receive your full identity data.
• Cloud infrastructure providers: Hosting and data storage providers who maintain the servers on which tuna55 platform data is stored, subject to strict data processing agreements.
• Analytics providers: Platform performance and fraud detection analytics services that process anonymized or pseudonymized technical data.
• Customer support tools: Live chat and ticket management platforms used to deliver our 24/7 support service.

7.2 Legal & Regulatory Disclosure

tuna55 may disclose personal data to regulatory authorities, law enforcement agencies, courts, or other governmental bodies where required or permitted by law — for example, in response to a lawful court order, a request from a financial intelligence unit, or to report suspected money laundering or fraud. Such disclosures will be limited to the minimum data necessary to satisfy the legal requirement.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of tuna55's business, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify affected Members in advance of any such transfer and ensure that the recipient entity agrees to honor this Privacy Policy or provide equivalent protections.

8 International Data Transfers

As an international online gaming platform, tuna55 may transfer personal data to servers, service providers, and partners located outside Indonesia. When personal data is transferred internationally, tuna55 ensures that appropriate safeguards are in place, including:

• Data processing agreements incorporating internationally recognized standard contractual clauses;
• Transfer only to recipients in jurisdictions that maintain data protection standards equivalent to those described in this Policy;
• Encryption of data in transit using industry-standard TLS/SSL protocols;
• Contractual obligations on recipients to process data solely for specified purposes and to implement appropriate technical and organizational security measures.

Where game studios such as Pragmatic Play or Evolution Gaming process session data on servers located outside Indonesia, such processing is governed by the data processing agreements between tuna55 and those providers, and is strictly limited to the purposes of game delivery and session integrity.

9 Data Retention

tuna55 retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable legal and regulatory obligations. Our standard retention periods are as follows:

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized so that it can no longer be attributed to any identifiable individual. Where data cannot be immediately deleted due to technical constraints, it will be isolated and protected from further processing until deletion is completed.

10 Data Security

tuna55 implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. Our security framework includes:

• Encryption in transit: All data transmitted between your device and tuna55 servers is encrypted using industry-standard TLS 1.2/1.3 (SSL) protocols. Our platform operates exclusively over HTTPS.
• Encryption at rest: Sensitive personal data and financial records stored on tuna55 servers are encrypted using AES-256 encryption.
• Access controls: Access to personal data is strictly limited to tuna55 personnel and authorized service providers who require it for their designated role. Access is governed by role-based access control (RBAC) and the principle of least privilege.
• Two-factor authentication (2FA): All tuna55 internal systems holding personal data require multi-factor authentication for staff access. Members are also encouraged to enable 2FA on their own Accounts.
• Penetration testing & security audits: tuna55 conducts regular security assessments, vulnerability scans, and third-party penetration tests to identify and remediate potential security weaknesses.
• Incident response: tuna55 maintains a documented data breach response plan. In the event of a data breach likely to result in risk to affected individuals, we will notify relevant authorities and affected Members in a timely manner in accordance with applicable data breach notification standards.

11 Cookies & Tracking Technologies

tuna55 uses cookies and similar tracking technologies to ensure the platform functions correctly, to improve user experience, and to gather analytics data. The following categories of cookies are used on the tuna55 platform:

11.1 Strictly Necessary Cookies

These cookies are essential for the platform to operate and cannot be disabled without impairing core functionality. They include session authentication tokens, security cookies, and load-balancing cookies. No consent is required for strictly necessary cookies.

11.2 Functional Cookies

These cookies remember your preferences and settings to provide a more personalized experience — for example, your preferred language display, previously entered username (for login convenience), and interface customization preferences. These cookies do not track your activity outside the tuna55 platform.

11.3 Analytics Cookies

With your consent, tuna55 uses analytics cookies to understand how Members interact with the platform — including which pages are visited most frequently, session duration, navigation paths, and error events. This data is used in aggregate and pseudonymized form to improve the platform. Analytics cookies are only activated where you have provided consent.

11.4 Managing Cookies

You may manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the tuna55 platform. Disabling strictly necessary cookies will prevent login and core platform features from operating correctly.

12 Your Rights

tuna55 respects your rights as a data subject. Subject to applicable law and certain regulatory limitations (for example, where data must be retained to comply with AML regulations), you have the following rights regarding your personal data:

• Right of Access: You may request a copy of the personal data tuna55 holds about you, together with information about how it is processed.
• Right to Rectification: You may request that inaccurate or incomplete personal data be corrected or updated. For certain data (such as your registered name), you may be required to provide supporting documentation.
• 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, where you have withdrawn consent, or where processing is unlawful — subject to our legal obligations to retain certain data for regulatory compliance.
• Right to Restriction of Processing: You may request that we restrict the processing of your personal data in certain circumstances — for example, while a dispute regarding data accuracy is being resolved.
• Right to Data Portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you may request that your personal data be provided to you in a structured, commonly used, machine-readable format.
• Right to Object: You may object to the processing of your personal data where processing is based on legitimate interests, including profiling for marketing purposes. You may opt out of marketing communications at any time.
• 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 withdrawal.

To exercise any of these rights, please contact tuna55 customer support via live chat or by email at [email protected] (plain text — not a clickable link). We will respond to all verified rights requests within 30 days. In certain complex cases, this period may be extended by a further 30 days, of which you will be notified.

13 Minors & Age Policy

The tuna55 platform is strictly intended for adults aged 21 years and above. tuna55 does not knowingly collect personal data from any person under the age of 21. As part of our KYC verification process, all Members are required to provide proof of age before withdrawal functionality is enabled.

If tuna55 becomes aware that personal data has been collected from a person under the age of 21 without verifiable parental or guardian consent, that data will be permanently deleted, the associated Account will be closed immediately, and any funds held in that Account will be handled in accordance with our Terms & Conditions and applicable regulations.

If you are a parent or guardian and believe your child has registered an Account on the tuna55 platform, please contact our customer support team immediately at [email protected] so we can investigate and take appropriate action without delay.

14 Third-Party Services

The tuna55 platform integrates with various third-party services to deliver a comprehensive betting and gaming experience. These include game studios (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft), payment processors, and analytics tools. Each of these providers operates independently and maintains its own privacy policy.

tuna55 takes reasonable steps to ensure that all third-party service providers engaged as Data Processors are bound by contractual data protection obligations consistent with this Privacy Policy. However, tuna55 cannot accept responsibility for the independent data practices of third-party controllers — such as your bank (BCA, BRI, BNI, Mandiri, etc.) or e-wallet provider (OVO, DANA, GoPay) — once data has been transmitted to those entities for payment processing purposes.

The tuna55 platform does not contain links to external websites other than those necessary for the delivery of integrated game content and payment processing. This Privacy Policy does not apply to any external websites or services not operated by tuna55.

15 Policy Amendments

tuna55 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, platform features, applicable legal requirements, or regulatory guidance. When material changes are made, tuna55 will notify registered Members by email or via an in-platform notification, with at least 7 days' advance notice before the revised Policy takes effect — except where immediate amendment is required by law or to address an urgent security risk.

The effective date displayed at the top of this page reflects the date of the most recent revision. We encourage you to review this Policy periodically to stay informed about how tuna55 protects your personal data. Your continued use of the platform after the effective date of a revised Policy constitutes your acceptance of the updated terms.

All previous versions of this Privacy Policy are archived and available upon request by contacting tuna55 customer support.

16 Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the way tuna55 processes your personal data, please contact our Data Protection team through any of the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 directly through the tuna55 platform
• Subject Line (for email): "Privacy Request – [Your Username]" to ensure prompt routing to our data protection team
• Response Time: We aim to acknowledge all privacy-related inquiries within 48 hours and to provide a substantive response within 30 days
• Languages: English and Bahasa Indonesia