Privacy Policy

This Privacy Policy governs the collection, processing, storage, and use of personal data by cinaxl, the online casino and sports betting platform accessible at https://cinaxl.cam. This policy applies to all users who access, browse, register on, or otherwise interact with the cinaxl platform, regardless of the device or interface used.

By creating an account or using any part of the cinaxl platform, you acknowledge that you have read, understood, and agreed to the practices and policies outlined in this document. If you do not agree with this Privacy Policy, you must immediately cease all use of the platform.

This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern your overall use of the platform. Where conflicts arise between documents, this Privacy Policy takes precedence on matters specifically relating to personal data processing.

cinaxl acts as the data controller for all personal information collected through the platform. As data controller, cinaxl determines the purposes and means of processing your personal data and is responsible for ensuring that all data handling complies with applicable data protection laws.

For data protection inquiries, you may contact our Data Protection Officer at the email address provided in the Contact Us section of this policy. All requests related to your personal data — including access requests, rectification requests, and deletion requests — will be processed in accordance with the procedures outlined in the "Your Rights" section below.

cinaxl collects personal data from multiple sources and across multiple stages of your interaction with the platform. The categories of personal data we collect include:

We do not collect sensitive personal data such as religious beliefs, political opinions, trade union membership, genetic data, or biometric data for unique identification purposes, except where facial verification is explicitly required for enhanced KYC processes and where you have provided express consent.

cinaxl processes your personal data for the following specific purposes:

• Account Management: To create, maintain, and administer your cinaxl account; to authenticate your identity during login; to manage your account settings and preferences.
• Service Delivery: To process your bets and wagers on sports betting (bandar bola), casino games, togel (traditional Indonesian numbers lottery), sabung ayam (cockfighting betting), and all other products offered on the platform; to calculate and credit winnings; to manage your wallet balance.
• Payment Processing: To process deposits via BCA, BRI, BNI, Mandiri, and other Indonesian banks, as well as e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja); to verify bank account ownership; to process withdrawal requests; to prevent payment fraud.
• Compliance & Verification: To verify that you are at least 21 years of age; to comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations; to prevent duplicate accounts; to detect and prevent fraud, collusion, and other prohibited activities.
• Customer Support: To respond to your inquiries, complaints, and support requests; to troubleshoot technical issues; to provide assistance with deposits, withdrawals, and gameplay questions.
• Marketing & Communications: To send promotional emails, SMS, and push notifications about bonuses, tournaments, and special offers (only if you have opted in); to personalize promotional content based on your gaming preferences; to notify you of platform updates and important account changes.
• Platform Improvement: To analyze user behavior and preferences to improve game selection, user interface, and overall platform experience; to conduct A/B testing on new features; to monitor platform performance and stability.
• Security & Fraud Prevention: To monitor for suspicious activity, unauthorized access attempts, and potential account takeover; to enforce our Terms & Conditions; to prevent bonus abuse and multi-accounting; to protect the integrity of games and betting markets.
• Legal Compliance: To comply with applicable gambling laws, tax reporting requirements, and regulatory obligations in the jurisdictions where cinaxl operates; to respond to lawful requests from law enforcement and regulatory authorities.

cinaxl processes your personal data under one or more of the following legal bases:

• Contractual Necessity: Processing is necessary to fulfill our contractual obligations to you under the Terms & Conditions, including delivering the services you have requested (account creation, bet processing, payment processing).
• Legal Obligation: Processing is required to comply with legal obligations imposed on cinaxl by gambling regulations, AML laws, tax laws, and other applicable legislation.
• Legitimate Interest: Processing is necessary for cinaxl's legitimate business interests, such as fraud prevention, platform security, service improvement, and internal analytics, provided these interests are not overridden by your fundamental rights and freedoms.
• Consent: Where processing is based solely on your consent (e.g., marketing communications), you have the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

cinaxl does not sell, rent, or trade your personal data to third parties for their independent marketing purposes. However, we may share your data with the following categories of third-party service providers under strict confidentiality and data protection obligations:

• Payment Processors: We share necessary payment information with Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, BSI) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) to process your deposit and withdrawal transactions.
• Game Providers: We share limited session data with third-party game studios (Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, Pocket Games Soft) to deliver live casino, slots, and other game content. These providers process data under their own privacy policies.
• KYC Verification Services: We may use third-party identity verification providers to authenticate your government-issued ID and validate your age and address. These providers are bound by strict data processing agreements.
• Customer Support Tools: We use third-party live chat and ticketing systems to manage customer support interactions. Chat transcripts and support history are stored securely within these systems.
• Cloud Hosting & Infrastructure: cinaxl platform infrastructure is hosted on secure cloud servers. Your data may be stored on servers operated by cloud service providers under data processing agreements that require adherence to industry-standard security practices.
• Marketing & Analytics Platforms: We use email marketing platforms to send promotional communications to opted-in users, and analytics tools to understand user behavior and improve the platform. These tools process anonymized or pseudonymized data wherever possible.
• Legal & Regulatory Authorities: We may disclose your personal data to law enforcement agencies, regulatory bodies, courts, or other government entities where required by law or where necessary to protect our legal rights, prevent fraud, or ensure platform integrity.

All third-party service providers are contractually required to process your data only for the specific purposes outlined above, to implement appropriate security measures, and to refrain from using your data for their own purposes.

cinaxl employs industry-standard technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or alteration. Our security measures include:

• SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS encryption protocols, ensuring that sensitive information (login credentials, payment details) cannot be intercepted during transmission.
• Secure Data Storage: Personal data is stored on secure, access-controlled servers located in certified data centers. Database encryption is applied to sensitive fields such as passwords (hashed using bcrypt), payment information, and KYC documents.
• Access Controls: Access to personal data is restricted on a need-to-know basis. Only authorized cinaxl employees and contractors with a legitimate business reason are granted access, and all access is logged and audited.
• Firewall & Intrusion Detection: Our platform infrastructure is protected by enterprise-grade firewalls and intrusion detection systems that monitor for suspicious activity and unauthorized access attempts in real time.
• Regular Security Audits: cinaxl undergoes periodic third-party security audits and penetration testing to identify and remediate vulnerabilities. All findings are addressed promptly according to severity.
• Employee Training: All cinaxl staff with access to personal data undergo mandatory data protection and security awareness training to ensure compliance with privacy policies and security protocols.

Despite these measures, no system is entirely immune to security breaches. In the event of a data breach that poses a risk to your rights and freedoms, cinaxl will notify affected users and relevant regulatory authorities without undue delay, in accordance with applicable data breach notification laws.

cinaxl retains your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, or as required by applicable laws and regulations. Specific retention periods include:

• Account Data: Retained for the duration of your active membership, plus an additional 7 years after account closure to comply with AML record-keeping requirements and to resolve potential disputes or claims.
• KYC Documents: Retained for 7 years after the last transaction or account closure, as required by Indonesian AML and financial crime prevention regulations.
• Transaction Records: Deposit, withdrawal, and bet history retained for 7 years to comply with financial auditing and tax reporting obligations.
• Communication Logs: Customer support transcripts and correspondence retained for 3 years for quality assurance and dispute resolution purposes.
• Marketing Data: Retained until you withdraw consent or unsubscribe from marketing communications, at which point your email address is added to a suppression list to prevent future contact.
• Technical Logs: Server logs, IP addresses, and session data retained for 12 months for security monitoring and fraud detection purposes, then anonymized or deleted.

After the applicable retention period expires, personal data is securely deleted or anonymized such that it can no longer be associated with an identifiable individual.

As a cinaxl user, you have the following rights regarding your personal data:

• Right of Access: You have the right to request a copy of all personal data we hold about you. We will provide this information in a structured, commonly used, machine-readable format within 30 days of your request.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data. Most account information can be updated directly via your account settings; for other data, please contact support.
• Right to Erasure (Right to be Forgotten): You have the right to request deletion of your personal data where: (a) the data is no longer necessary for the purposes for which it was collected; (b) you withdraw consent (where processing was based on consent); (c) you object to processing based on legitimate interests and there are no overriding legitimate grounds. This right is subject to legal retention obligations (e.g., AML record-keeping requirements).
• Right to Restriction of Processing: You have the right to request that we temporarily suspend processing of your personal data in certain circumstances, such as when you contest the accuracy of data or when processing is unlawful but you prefer restriction over deletion.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used format and to transmit that data to another service provider where technically feasible.
• Right to Object: You have the right to object to processing of your personal data where processing is based on legitimate interests. You may object to direct marketing at any time by clicking the unsubscribe link in promotional emails or by contacting support.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred prior to withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority (data protection regulator) if you believe that cinaxl has violated your data protection rights.

To exercise any of these rights, please contact our Data Protection Officer at support@cinaxl.cam with "Data Protection Request" in the subject line. We will respond to all requests within 30 days and may require identity verification before processing certain requests.

cinaxl uses cookies and similar tracking technologies to enhance your experience on the platform. Cookies are small text files stored on your device that allow us to recognize you, remember your preferences, and analyze platform usage.

Types of cookies we use:

• Essential Cookies: Strictly necessary for the platform to function. These cookies enable core features such as account login, session management, and secure transaction processing. Essential cookies cannot be disabled.
• Functional Cookies: Remember your preferences (language, time zone, layout settings) to provide a more personalized experience. These cookies do not track you across other websites.
• Analytics Cookies: Help us understand how users interact with the platform by collecting anonymized usage data (pages visited, time spent, click patterns). We use this data to identify areas for improvement.
• Marketing Cookies: Track your activity across sessions to deliver personalized promotional content and to measure the effectiveness of advertising campaigns. These cookies are set only if you have opted in to marketing communications.

You may manage cookie preferences through your browser settings. Disabling essential cookies will prevent you from using core platform features. For detailed instructions on managing cookies in your specific browser, please refer to your browser's help documentation.

cinaxl strictly enforces a 21+ age restriction in accordance with responsible gambling principles and Indonesian market standards. The platform is not intended for use by individuals under 21 years of age, and we do not knowingly collect personal data from minors.

If we become aware that we have inadvertently collected personal data from an individual under 21 years of age, we will take immediate steps to delete that data and permanently close the associated account. All deposits made by underage users will be returned to the payment source, and any winnings will be forfeited.

Parents and guardians are encouraged to supervise their children's internet use and to implement parental control software to restrict access to gambling websites. If you have reason to believe that an underage individual has accessed cinaxl, please contact us immediately at support@cinaxl.cam with "Underage Access Report" in the subject line.

cinaxl reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or platform features. Material changes — those that significantly affect your rights or how we process your data — will be communicated to you via email to your registered email address at least 7 days before the changes take effect.

Non-material changes (clarifications, formatting updates, minor corrections) may be implemented immediately upon posting the revised policy on this page. The "Last Updated" date at the top of this document indicates when the policy was most recently revised.

Continued use of the cinaxl platform after the effective date of any changes constitutes acceptance of the revised Privacy Policy. If you do not agree with the updated policy, you must cease using the platform and may request account closure and data deletion in accordance with the procedures outlined in the "Your Rights" section.

For any questions, concerns, or requests related to this Privacy Policy or our data protection practices, please contact our Data Protection Officer using the following channels:

• Email: support@cinaxl.cam (use subject line "Privacy Inquiry" or "Data Protection Request")
• Live Chat: Available 24/7 via the platform interface — request to speak with a data protection specialist
• Response Time: We aim to respond to all privacy inquiries within 48 hours during business hours (WIB, UTC+7)

For formal data subject access requests, please include "Data Subject Access Request" in the subject line and provide sufficient information to verify your identity. We may request additional verification documents before processing certain requests to ensure data security.