Privacy Policy — mata11

mata11 ("we", "us", "our") operates the online betting and casino platform accessible at https://mata11.cam (the "Platform"). We are committed to protecting the privacy and personal data of all individuals who interact with our Platform, whether as registered Members or as visitors.

This Privacy Policy sets out, in clear and accessible terms, the categories of personal data we collect, the lawful bases on which we process that data, the purposes for which it is used, with whom it may be shared, how long we retain it, and the rights available to you as a data subject.

This Privacy Policy applies to all residents of Indonesia and all other individuals who use the mata11 Platform regardless of geographic location. It applies to data collected through our website, mobile-optimised browser interface, customer support channels (including live chat, WhatsApp, and email at [email protected]), and any other mata11-branded communication channel.

This Privacy Policy should be read together with our Terms & Conditions and our Responsible Gaming policy, both of which form part of the overall framework governing your relationship with mata11.

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" means any information that relates to an identified or identifiable natural person, including name, national identity number, email address, payment account details, IP address, and betting history.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, deletion, or anonymisation.
• "Data Controller" means mata11, which determines the purposes and means of Processing Personal Data.
• "Data Processor" means a third party that processes Personal Data on behalf of mata11 under a written data processing agreement (e.g., payment service providers, KYC verification vendors, cloud hosting providers).
• "Member" means an individual who has registered a verified account on the mata11 Platform.
• "KYC" means Know Your Customer — the identity verification process required by AML regulations.
• "Cookies" means small text files placed on your device by the Platform to enable session management, preference storage, and analytics.
• "IDR / Rp" means Indonesian Rupiah, the currency of account on the Platform.

mata11 collects the following categories of Personal Data from Members and Platform visitors:

mata11 collects Personal Data through the following means:

• Direct submission: Data you voluntarily provide when registering an account, completing KYC verification, making a deposit or withdrawal request, contacting customer support, or updating your account profile.
• Automated technical collection: When you access or use the Platform, our servers and analytics tools automatically record Technical Data (IP address, device type, browser, session data) via server logs, Cookies, and similar technologies.
• Payment service providers: When you transact via BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, OVO, GoPay, DANA, ShopeePay, or LinkAja, we receive confirmation data (transaction reference, masked account identifier, amount, and timestamp) from those providers. We do not receive or store your full bank account PIN or mobile banking password.
• KYC and identity verification partners: Third-party KYC service providers may pass verification outcomes and document authenticity assessments back to mata11, enriching the identity record we hold for complia nce purposes.
• Third-party fraud prevention tools: We use fraud detection and risk-scoring services that analyse betting patterns, transaction behaviour, and device fingerprints to protect both Members and the Platform from fraudulent activity.
• Public sources: In limited circumstances, such as during fraud investigations or when required by law, mata11 may supplement its records with publicly available data (e.g., corporate registry records, law enforcement bulletins, self-exclusion lists published by gaming authorities).

mata11 processes Personal Data only where we have a lawful basis to do so. The legal bases on which we rely are:

1. Contractual necessity: Processing is necessary to perform the contract between you and mata11 (i.e., the Terms & Conditions you accepted when registering). This includes account creation, deposit and withdrawal processing, bet settlement, bonus crediting, and customer support.
2. Legal obligation: Processing is required to comply with applicable laws, regulations, or orders from competent authorities. This includes Know Your Customer (KYC) obligations under anti-money-laundering (AML) law, age verification to prevent underage gambling, tax reporting, and responding to lawful requests from law enforcement or gaming regulators.
3. Legitimate interests: Processing is necessary for mata11's legitimate business interests, provided those interests are not overridden by your fundamental rights and freedoms. Legitimate interests include fraud prevention and platform security, risk management and responsible gaming monitoring, analytics to improve the Platform user experience, and investigating breaches of the Terms & Conditions.
4. Consent: Where required by law or where no other lawful basis applies, we will obtain your explicit consent before processing Personal Data. For example, consent is required before sending you promotional email newsletters. You may withdraw consent at any time via your account settings or by contacting [email protected].

Where we rely on legitimate interests, you have the right to object to such processing at any time. See Clause 11 (Your Privacy Rights) for details.

mata11 processes Personal Data for the following specific purposes:

• Account management: To create, maintain, and administer your mata11 account; to authenticate your identity at login; to apply account settings and preferences you have selected (language, deposit limits, notifications).
• Payment processing: To process deposits to your account Balance and withdrawals to your registered bank account or e-wallet; to reconcile transactions; to investigate disputed or failed transactions; to refund stakes where required under the Terms & Conditions.
• KYC and age verification: To verify your identity, age (21+ requirement), and residency; to confirm ownership of the payment methods you use; to detect and prevent identity theft, synthetic identity fraud, and other forms of account takeover.
• Bet settlement and game provision: To accept, record, and settle wagers on sports betting (including bandar bola, football betting markets), casino games, togel, slot gacor, sabung ayam (traditional Indonesian cockfighting streaming), and e-sports; to calculate winnings and losses; to enforce betting limits and game rules.
• Bonus and promotion administration: To award bonuses, free bets, and promotional credits; to track wagering requirements and bonus expiry; to prevent bonus abuse and multi-accounting.
• Customer support: To respond to inquiries, complaints, and support requests via live chat, email, or WhatsApp; to investigate and resolve disputes; to escalate unresolved issues to management.
• Fraud prevention and platform security: To detect unusual betting patterns, coordinated syndicate play, arbitrage exploitation, automated bot activity, and other forms of abuse prohibited under Clause 9 of the Terms & Conditions; to block access from jurisdictions where online gambling is unlawful; to protect the integrity of game outcomes and odds.
• Responsible gaming: To monitor for signs of problem gambling behaviour (e.g., chasing losses, escalating bet sizes, frequent deposit-loss cycles); to enforce self-exclusion and cooling-off periods; to apply deposit limits and session time limits set by you or recommended by our responsible gaming team. See our Responsible Gaming policy for further information.
• Legal and regulatory compliance: To maintain records as required under gaming licensing conditions and AML regulations; to respond to lawful requests from law enforcement, tax authorities, and gaming regulators; to file suspicious activity reports (SARs) where appropriate; to defend mata11's legal rights in the event of a dispute or litigation.
• Analytics and service improvement: To understand how Members use the Platform; to identify popular games and betting markets; to optimise page load times and mobile responsiveness; to A/B test new features and user interface improvements. All analytics are conducted on aggregated or anonymised data wherever possible.
• Marketing (with consent): To send you promotional offers, bonus announcements, tournament invitations, and other marketing communications where you have given explicit consent. You may opt out at any time via the unsubscribe link in any email, via your account notification settings, or by contacting [email protected].

mata11 does not sell, rent, or trade your Personal Data to any third party for their own marketing or commercial purposes. We do, however, disclose Personal Data to the following categories of recipients where necessary to operate the Platform and comply with legal obligations:

• Payment service providers: Your Financial Data is shared with payment processors and banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, Bank Permata) and e-wallet providers (OVO, GoPay, DANA, ShopeePay, LinkAja) solely to execute deposit and withdrawal transactions. These processors act as Data Processors under contractual obligations to protect your data.
• KYC and identity verification vendors: KYC Documents and Identity Data are shared with third-party verification services to authenticate your identity documents, perform liveness checks on selfies, and cross-reference against fraud databases. These vendors are bound by data processing agreements and data protection law.
• Game studios and software providers: When you play casino games or slot gacor from studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, or Pocket Games Soft, a unique session identifier and your username (but not your full Identity Data) may be passed to the game server to enable play. These studios do not receive your KTP number, financial data, or contact details.
• Fraud detection and security vendors: Technical Data and Betting & Gaming Data may be analysed by third-party fraud detection platforms to generate risk scores and detect suspicious activity. These platforms operate under strict confidentiality obligations.
• Cloud infrastructure providers: mata11 uses cloud hosting services for data storage and platform delivery. All data stored with cloud providers is encrypted at rest and in transit, and providers are subject to industry-standard security certifications.
• Law enforcement and regulatory bodies: mata11 may disclose Personal Data where required by law, court order, or binding regulatory request. This includes responding to lawful requests from Indonesian law enforcement, the gaming regulatory authority in our licensing jurisdiction, or tax authorities. We will not voluntarily disclose data beyond what is legally required.
• Legal and professional advisors: In the event of a dispute, litigation, or regulatory investigation, mata11 may share relevant Personal Data with external legal counsel, auditors, and compliance consultants under attorney-client privilege and professional confidentiality obligations.
• Business successors: In the event mata11 undergoes a merger, acquisition, restructuring, or sale of assets, Personal Data may be transferred to the acquiring entity, provided the acquiring entity agrees to honour the terms of this Privacy Policy.

mata11 retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected or as required by law. Specific retention periods are:

• Identity Data and KYC Documents: Retained for the duration of your account plus seven (7) years after account closure to meet AML and gaming licensing record-keeping requirements.
• Financial Data and transaction records: Retained for seven (7) years after the last transaction for tax, audit, and regulatory compliance purposes.
• Betting & Gaming Data: Retained for five (5) years after the wager is settled to support dispute resolution, regulatory reporting, and responsible gaming monitoring.
• Technical Data (IP logs, session logs): Retained for ninety (90) days unless flagged as part of a fraud investigation, in which case the data is retained for the duration of the investigation plus one (1) year.
• Communications Data (live chat, email): Retained for three (3) years to support customer service quality assurance and to defend against complaints or disputes.
• Marketing consent records: Retained for three (3) years after you withdraw consent or close your account.

At the end of the applicable retention period, Personal Data is either securely deleted or irreversibly anonymised such that it can no longer identify you. Anonymised data may be retained indefinitely for statistical analysis and platform improvement.

If you close your account or request deletion of your data before the end of the standard retention period, mata11 will anonymise your data where legally permissible, but cannot delete data that must be retained under AML, tax, or gaming licensing law.

mata11 implements technical and organisational security measures to protect Personal Data against unauthorised access, accidental loss, destruction, or damage. These measures include:

• TLS 1.3 encryption: All data transmitted between your device and mata11 servers is encrypted using Transport Layer Security (TLS) 1.3, the latest industry-standard protocol.
• AES-256 encryption at rest: Sensitive Personal Data, including KYC Documents and Financial Data, is encrypted at rest using AES-256 encryption on secured cloud infrastructure.
• Access controls: Personal Data is accessible only to authorised mata11 personnel and Data Processors on a need-to-know basis, subject to role-based access controls and audit logging.
• Multi-factor authentication (MFA): mata11 administrative and development systems are protected by multi-factor authentication to prevent unauthorised access by insiders or external attackers.
• Intrusion detection and prevention: Our infrastructure is monitored 24/7 by automated intrusion detection systems (IDS) and web application firewalls (WAF) to detect and block malicious activity.
• Regular security audits: mata11 undergoes annual third-party security audits and penetration testing to identify and remediate vulnerabilities before they can be exploited.
• Secure payment integration: Deposits and withdrawals are processed through PCI DSS-compliant payment gateways. mata11 does not store full credit card numbers, card security codes (CVV), or banking PINs.
• Employee training: All mata11 staff with access to Personal Data receive mandatory training on data protection principles, phishing awareness, and incident response procedures.

The mata11 Platform uses Cookies and similar tracking technologies to provide core functionality, enhance user experience, and generate analytics. A Cookie is a small text file stored on your device that allows the Platform to recognise you on subsequent visits.

Types of Cookies we use:

• Strictly necessary Cookies: These enable core Platform functions such as secure login, session management, and shopping-cart functionality. The Platform cannot operate without these Cookies, and they are set automatically. No consent is required as they are essential for contractual performance.
• Performance and analytics Cookies: These collect anonymised data about how Members use the Platform (pages visited, session duration, bounce rate) to help us identify technical issues and improve site performance. We use tools such as Google Analytics with IP anonymisation enabled.
• Functional Cookies: These remember your preferences (language, time zone, deposit method) so you do not have to re-enter them on every visit. Functional Cookies enhance user experience but are not strictly necessary.
• Fraud prevention Cookies: These generate a device fingerprint to help detect and prevent multi-accounting, bot activity, and other prohibited conduct under Clause 9 of the Terms & Conditions.

We do not use advertising or retargeting Cookies. mata11 does not engage in behavioural advertising or share Cookie data with advertising networks or social media platforms for tracking purposes.

You can control Cookie settings via your browser. Most browsers allow you to refuse all Cookies or to be notified when a Cookie is set. However, disabling strictly necessary Cookies will prevent you from logging in or placing wagers. Disabling analytics or functional Cookies may degrade your user experience but will not prevent basic Platform use.

As a data subject whose Personal Data is processed by mata11, you have the following rights under internationally recognised data protection principles:

• Right to access: You may request a copy of the Personal Data we hold about you. We will provide this in a commonly used electronic format within thirty (30) days of your request.
• Right to rectification: If any Personal Data we hold about you is inaccurate, incomplete, or out of date, you may request that we correct it. You can update most information directly via your account settings.
• Right to erasure (right to be forgotten): You may request that we delete your Personal Data where: (a) it is no longer necessary for the purposes for which it was collected; (b) you withdraw consent (where consent was the lawful basis); (c) you object to processing based on legitimate interests and no overriding legitimate grounds exist; or (d) the data was unlawfully processed. This right is subject to our legal and regulatory retention obligations under Clause 8.
• Right to restriction of processing: You may request that we temporarily suspend processing of your Personal Data where: (a) you contest the accuracy of the data; (b) the processing is unlawful but you do not want the data erased; (c) we no longer need the data but you require it for a legal claim; or (d) you have objected to processing and verification of our legitimate grounds is pending.
• Right to data portability: Where technically feasible, you may request that we provide your Personal Data in a structured, commonly used, machine-readable format so you can transfer it to another service provider.
• Right to object: You may object at any time to processing based on legitimate interests (including for direct marketing purposes). We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is necessary for legal claims.
• Right to withdraw consent: Where we process your Personal Data based on consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.
• Right to lodge a complaint: If you believe mata11 has processed your Personal Data in breach of applicable data protection law, you may lodge a complaint with the data protection supervisory authority in your jurisdiction or the jurisdiction in which mata11 is established.

To exercise any of these rights, contact mata11 at [email protected] with the subject line "Privacy Rights Request" and specify which right you wish to exercise. We will respond within thirty (30) days. Proof of identity (e.g., a copy of your KTP) may be required to prevent unauthorised disclosure of Personal Data.

The mata11 Platform is intended exclusively for adults aged 21 years or older. We do not knowingly collect Personal Data from individuals under the age of 21.

If we become aware that an individual under 21 has registered an account or provided Personal Data to mata11, we will immediately suspend the account, void all pending and settled wagers, refund the deposited funds (minus any winnings, which are forfeited), and delete the Personal Data from our systems in accordance with legal retention requirements.

Parents and guardians are encouraged to monitor the online activity of minors under their care. If you believe a minor has accessed mata11, please contact us immediately at [email protected] so we can take appropriate action.

The mata11 Platform may contain links to third-party websites or services (for example, payment provider login portals, game studio websites, or responsible gaming support organisations). mata11 is not responsible for the privacy practices or content of these third-party sites.

When you click a link that takes you away from mata11.cam, you leave our Platform and this Privacy Policy no longer applies. We encourage you to read the privacy policy of every website you visit.

mata11 carefully selects its Data Processors and requires them to comply with data protection law, but we cannot guarantee the practices of third parties beyond our direct control. If you have concerns about a third-party service used by mata11, contact us at [email protected].

mata11 operates an international platform and stores Personal Data on cloud infrastructure that may be located outside Indonesia. By using the mata11 Platform, you acknowledge that your Personal Data may be transferred to, stored in, and processed in jurisdictions outside Indonesia where data protection laws may differ from those in Indonesia.

Where Personal Data is transferred internationally, mata11 ensures that appropriate safeguards are in place, including: (a) transferring data only to jurisdictions recognised as providing adequate data protection; (b) entering into standard contractual clauses with Data Processors; or (c) relying on the processor's certification under recognised international privacy frameworks.

All international transfers comply with the data protection requirements of mata11's gaming licensing jurisdiction and, to the extent applicable, international standards such as GDPR.

mata11 may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal requirements, or Platform features. Where material changes are made, we will notify you via email to your registered address and/or via a prominent notice on the Platform at least fourteen (14) days before the updated policy takes effect.

Your continued use of the mata11 Platform after the effective date of an updated Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the updated Privacy Policy, you must cease using the Platform and, if you hold a real-money Balance, submit a withdrawal request in accordance with Clause 6 of the Terms & Conditions.

The current version of this Privacy Policy is always available at https://mata11.cam/privacy-policy and is dated at the top of the document. We recommend reviewing this page periodically to stay informed of any changes.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your Personal Data, you may contact mata11 using any of the following channels:

• Email: [email protected] (subject line: "Privacy Inquiry")
• Live Chat: Available 24/7 on the mata11 Platform — simply click the chat icon in the bottom-right corner of any page.
• WhatsApp: +62 811 0000 1411 (Indonesian-speaking support agents available 24/7, all times WIB)

Our customer support team typically responds to privacy inquiries within twenty-four (24) hours during business days. For formal privacy rights requests under Clause 11, please allow up to thirty (30) days for a full response.

mata11 is committed to resolving all privacy concerns in a fair, transparent, and timely manner. If you are not satisfied with our response, you have the right to escalate your complaint to the data protection supervisory authority in your jurisdiction.