Privacy Policy — sgabos

1Definitions

In this Privacy Policy, the following terms carry the meanings defined below:

• "Platform" means the sgabos website at https://sgabos.cam, all sub-pages, mobile views, and any associated software applications.
• "sgabos," "we," "us," "our" means the operating entity behind the sgabos brand, responsible for the collection and processing of personal data described in this Policy.
• "Player," "you," "your" means any individual who visits, registers on, or transacts through the Platform.
• "Personal Data" means any information that identifies or can reasonably be used to identify a living individual, including name, date of birth, email address, phone number, IP address, and payment details.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, and deletion.
• "Data Controller" means sgabos, which determines the purposes and means of processing your Personal Data.
• "Third-Party Processor" means any external company engaged by sgabos to process Personal Data on our behalf, such as payment gateway providers, KYC verification services, and customer support platforms.
• "Cookies" means small text files placed on your device by the Platform for session management, preference retention, and analytics purposes.

2Data We Collect

sgabos collects two broad categories of personal data: information you provide directly, and information generated automatically through your use of the Platform.

Information You Provide Directly:

• Registration Data: Full legal name, date of birth, Indonesian residential address, email address, and mobile phone number provided when creating your Account.
• Identity Verification (KYC) Data: Copy of your KTP (Indonesian national identity card), proof of address, and a selfie photograph submitted to satisfy our KYC obligations.
• Payment Data: Bank account details (bank name, account number, account holder name) or e-wallet identifiers (OVO, DANA, GoPay) used for deposits and withdrawals. Full payment credentials are handled by our certified payment processors — sgabos does not store raw card numbers or full bank account passwords.
• Communications Data: Content of messages sent to our customer support team via live chat, email, or any other support channel.
• Responsible Gaming Data: Self-imposed limits, self-exclusion requests, and any other data you submit in connection with our responsible gaming tools.

Information Collected Automatically:

• Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited, time and duration of sessions, betting and wagering history, game activity, and navigation patterns within the Platform.
• Cookie and Tracking Data: Session identifiers, preference settings, and analytical data collected via cookies and similar technologies (see Section 7).
• Geolocation Data: Approximate geographic location derived from your IP address, used to apply any applicable regional access restrictions.

3How We Collect Data

We collect your personal data through the following means:

• Direct Submission: When you complete the registration form, submit KYC documents, make a deposit or withdrawal request, or contact customer support.
• Automated Collection: Through cookies, web beacons, log files, and similar technologies that are activated when you access and navigate the Platform (see Section 7).
• Third-Party Sources: From our identity verification partners and payment processing providers, who may return supplementary identity or fraud-risk information as part of our KYC and AML compliance processes.
• Publicly Available Sources: In limited circumstances, we may verify information against publicly available records as part of due-diligence or fraud-prevention checks.

4How We Use Your Data

sgabos uses the personal data we collect for the following purposes:

We will never use your personal data for purposes that are incompatible with those listed above without providing prior notice and, where required, obtaining your consent.

5Legal Basis for Processing

Our processing of your personal data is grounded in one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing that is required to perform the contract between you and sgabos — specifically, to operate your account, accept wagers, process payments, and deliver customer support.
• Legal Obligation: Processing required by applicable law or regulation, including KYC and AML compliance obligations imposed by our licensing jurisdiction.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement — in each case where those interests are not overridden by your privacy rights.
• Consent: Processing for optional marketing communications, which you may withdraw at any time by contacting [email protected] or using the unsubscribe option in any marketing email.

6Data Sharing & Disclosure

sgabos does not sell, rent, or trade your personal data. We share your data only in the following limited and controlled circumstances:

• Payment Processors: We share necessary payment and identity data with our certified payment gateway providers (supporting BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, and GoPay transactions) to process your deposits and withdrawals. These providers are bound by strict data processing agreements.
• Identity Verification Partners: KYC document data is shared with our accredited identity verification service providers solely for the purpose of verifying your identity and complying with AML obligations.
• Customer Support Platforms: Communication data may be processed by our third-party live chat and support ticketing provider. Such providers operate under data processing agreements that restrict use of your data to service delivery only.
• Game Content Providers: Studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive anonymized session identifiers for the purpose of game performance and fairness auditing. No personally identifiable information is shared.
• Legal and Regulatory Authorities: We will disclose personal data to law enforcement, regulatory bodies, or courts where we are legally obligated to do so, or where disclosure is necessary to protect our rights, prevent fraud, or protect the safety of our players and staff.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of our business, player personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments being maintained.

7Cookies & Tracking Technologies

The sgabos Platform uses cookies and similar tracking technologies to deliver a functional, personalized, and secure user experience. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in, security tokens, and load-balancing cookies. These cannot be disabled without impairing core Platform functionality.
• Preference Cookies: Store your selected preferences such as language settings and display options so that the Platform remembers your choices between sessions.
• Analytics Cookies: Collect anonymized data about how visitors navi gate and use the Platform — pages visited, session duration, error events — to help us understand usage patterns and improve the user experience. No personally identifiable information is included in analytics data.
• Security Cookies: Used to detect and prevent fraudulent activity, including bot traffic, credential-stuffing attempts, and suspicious session behavior.

By continuing to use the Platform after being presented with our cookie notice, you consent to the use of the cookie categories described above. You may manage or disable non-essential cookies through your browser settings at any time; however, disabling strictly necessary cookies will affect Platform functionality and your ability to log in.

8Data Retention

sgabos retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory, or contractual obligations. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized. Where data is anonymized rather than deleted, it may be retained indefinitely for statistical or analytical purposes, as it can no longer be used to identify you.

9Data Security

sgabos implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. Our security framework includes:

• Encryption in Transit: All data transmitted between your browser or device and our servers is encrypted using TLS 1.2 or higher (256-bit SSL). This applies to all pages of the Platform, not just login and payment screens.
• Encryption at Rest: Stored personal and financial data is encrypted using AES-256 encryption on our database servers. Encryption keys are managed separately from the encrypted data.
• Access Controls: Access to personal data is restricted to authorized sgabos personnel who require it to perform their job functions. Role-based access controls and multi-factor authentication are enforced for all staff accessing sensitive systems.
• Regular Security Audits: Our platform undergoes regular penetration testing and vulnerability assessments conducted by independent third-party security specialists.
• Fraud Monitoring: Automated systems continuously monitor account activity for suspicious behavior, including unusual login patterns, rapid withdrawal requests following large deposits, and indicators of account takeover.
• Incident Response: sgabos maintains a documented data breach response plan. In the event of a confirmed breach affecting your personal data, we will notify you via your registered email address within a reasonable timeframe and provide guidance on protective steps you can take.

While we take every reasonable precaution to protect your data, no internet-based system can guarantee absolute security. You share responsibility for your account security by maintaining strong, unique passwords and enabling two-factor authentication where available.

10Your Privacy Rights

Subject to applicable law and the verification of your identity, you have the following rights in relation to the personal data sgabos holds about you:

• Right of Access: You may request a copy of the personal data we hold about you. We will provide this within 30 days of a verified request, free of charge for the first request in any 12-month period.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You may also update certain account details directly through your account settings.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, and where no overriding legal obligation requires us to retain it. Note that we are legally required to retain certain data for up to five years post-account-closure under our AML obligations, which may limit this right in practice.
• Right to Restriction of Processing: You may request that we restrict our processing of your personal data in certain circumstances — for example, while the accuracy of data is being contested.
• Right to Data Portability: You may request that we provide your personal data in a structured, commonly used, machine-readable format so that you can transfer it to another service provider.
• Right to Object: You may object to processing based on our legitimate interests at any time. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests, or unless the processing is necessary for legal claims.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

11Minors & Age Restriction

The sgabos Platform is strictly intended for adults who are at least 21 years of age. We do not knowingly collect personal data from individuals under the age of 21. The minimum age of 21 is enforced in line with responsible gaming standards applicable to the Indonesian market.

During the registration process, all users are required to confirm that they are 21 years of age or older. KYC verification, which includes submission of a government-issued identity document showing date of birth, provides a secondary layer of age verification prior to any withdrawal being processed.

If we become aware that personal data has been collected from an individual under the age of 21, that account will be closed immediately, all associated funds will be held pending investigation, and the personal data will be deleted in accordance with our data retention obligations. If you believe a minor may have created an account on our Platform, please notify us immediately at [email protected].

12Third-Party Services

The sgabos Platform integrates with a number of third-party services necessary to deliver a complete betting and gaming experience. These include game content providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft), payment infrastructure partners, and customer communication tools.

Each third-party provider operates under its own privacy policy and data processing terms. Where these providers process personal data on our behalf, we ensure that appropriate data processing agreements are in place, contractually requiring them to handle your data in accordance with applicable data protection standards.

sgabos is not responsible for the privacy practices of websites, services, or applications that are not under our direct control, including any third-party links that may appear in our communications. We encourage you to review the privacy policies of any third-party service you interact with independently of the sgabos Platform.

13International Data Transfers

As an internationally operated platform serving players primarily based in Indonesia, sgabos may transfer your personal data to servers or service providers located outside of Indonesia. Such transfers are necessary to operate the Platform effectively and to engage the specialized technology partners required for payment processing, identity verification, and game delivery.

When personal data is transferred internationally, sgabos takes steps to ensure that an adequate level of data protection is maintained. These steps may include:

• Transferring data only to countries or recipients that provide a comparable level of data protection to that applicable under our licensing jurisdiction.
• Implementing contractual clauses (standard data protection clauses) with recipient organizations that bind them to process your data only in accordance with our instructions and applicable data protection law.
• Conducting due diligence on international processors to verify that their security standards meet our requirements before data is transferred.

By using the sgabos Platform and submitting your personal data, you acknowledge that your data may be transferred to, stored, and processed in jurisdictions outside Indonesia as described in this section.

14Amendments to This Policy

sgabos reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or business operations. The "Last Updated" date at the top of this page will be revised whenever material changes are made.

Where changes are material — meaning they significantly affect how we collect, use, or share your personal data — we will notify you in advance via your registered email address and display a prominent notice on the Platform, allowing a minimum of 14 days before the updated Policy takes effect. For minor or non-material changes (such as typographical corrections or clarifications that do not alter the substance of our data practices), the revised Policy takes effect immediately upon publication.

Your continued use of the Platform following the effective date of any revised Privacy Policy constitutes your acknowledgment of the updated terms. If you do not agree to the revised Policy, please discontinue use of the Platform and contact [email protected] to request account closure and deletion of your personal data (subject to our legal retention obligations).

15Contact & Data Enquiries

If you have any questions, concerns, or requests relating to this Privacy Policy or the way in which sgabos processes your personal data, please reach out to our dedicated Data Privacy team using the contact details below:

For questions about your account, deposits, withdrawals, or general Platform use, please visit our FAQ page. For information about your rights and obligations as a player, including bonus terms and account rules, please review our Terms & Conditions.