Privacy Policy

Throughout this Policy, the following terms carry the meanings set out below:

as1131 collects personal data that is necessary to provide a safe, compliant, and high-quality gaming experience. The categories of personal data we collect include:

We collect only the minimum data required for the stated purpose. We do not collect sensitive categories of data such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data, or health data, except where strictly required by applicable law or where you voluntarily disclose such information in a support communication.

as1131 collects your personal data through the following channels:

• Direct interactions: Data you provide when creating an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in a promotion.
• Automated platform interactions: Technical data collected automatically when you visit the as1131 platform, including server log files, cookies, pixel tags, and similar tracking technologies.
• Payment processors and banking partners: Transaction confirmation data received from payment networks when you deposit or withdraw via Indonesian banks (BCA, BRI, BNI, Mandiri, etc.) or e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja).
• Identity verification partners: Where as1131 uses a third-party KYC service provider to validate documents you submit, that provider may return verification status data and fraud-risk scores to as1131.
• Fraud prevention and analytics services: Aggregated or pseudonymized behavioral data received from fraud detection tools and analytics platforms used to maintain the integrity of the as1131 platform.

as1131 processes your personal data only where a valid lawful basis exists. The bases we rely on are as follows:

• Contractual necessity: Processing required to fulfil our obligations under the Terms & Conditions — for example, creating and managing your account, processing deposits and withdrawals, and settling bets.
• Legal obligation: Processing required to comply with applicable anti-money laundering (AML) regulations, KYC obligations, age verification requirements, and any lawful request from competent authorities.
• Legitimate interests: Processing carried out for our legitimate business interests where those interests are not overridden by your fundamental rights — for example, fraud prevention, platform security, abuse detection, and internal analytics for service improvement.
• Consent: Processing based on your freely given, specific, and informed consent — for example, sending you promotional emails, push notifications, or personalized bonus offers. You may withdraw consent at any time without affecting the lawfulness of prior processing.

as1131 uses your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your player account, including password reset and session management.
• Identity and age verification: Confirming that you are at least 21 years of age and that your identity matches the payment methods associated with your account, in compliance with our KYC obligations.
• Transaction processing: Facilitating deposits and withdrawals in Indonesian Rupiah (IDR) via your chosen bank or e-wallet, and maintaining accurate financial records of all platform transactions.
• Customer support: Responding to your enquiries, resolving account issues, processing responsible gaming requests (such as deposit limits and self-exclusion), and maintaining records of support interactions.
• Responsible gaming: Monitoring account activity for signs of problem gambling behavior and, where appropriate, proactively contacting players or applying protective limits in accordance with our Responsible Gaming Policy.
• Fraud prevention and security: Detecting and investigating suspicious activity, preventing unauthorized account access, and enforcing our Terms & Conditions across the platform.
• Platform improvement: Analyzing aggregated behavioral and technical data to improve game offerings, user experience, platform stability, and promotional relevance.
• Marketing communications: Sending you personalized promotional offers, bonus notifications, and platform news where you have provided consent, and measuring the effectiveness of our campaigns.
• Legal and regulatory compliance: Retaining records and responding to lawful requests from competent regulatory or law-enforcement authorities as required under applicable international operating licences.

as1131 does not use your personal data to make fully automated decisions that produce legal or similarly significant effects without human review. Where automated tools are used in fraud detection or bonus-abuse identification, a trained compliance officer reviews all consequential decisions before any account action is taken.

as1131 does not sell, rent, or trade your personal data. We may share your data only in the following limited circumstances:

• Service providers and data processors: Carefully selected third-party vendors who process data on our behalf under binding data-processing agreements — including payment processors, KYC verification providers, fraud detection platforms, cloud hosting infrastructure providers, and customer support tools. These parties are permitted to use your data only for the specific purpose for which it was shared and are required to maintain confidentiality and security standards equivalent to our own.
• Payment network partners: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata) and e-wallet operators (OVO, DANA, GoPay, ShopeePay, LinkAja) receive only the transaction data necessary to process your deposit or withdrawal request.
• Game content providers: Software studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive a pseudonymized session identifier to facilitate game-round settlement. These providers do not receive your full name, contact details, or financial data.
• Legal and regulatory authorities: We may disclose personal data where required to do so by applicable law, court order, or lawful request from a competent government authority. Where permitted, we will inform you of any such disclosure.
• Business transfers: In the event of a merger, acquisition, or sale of assets involving as1131, personal data held by us may be transferred to the acquiring entity, subject to equivalent privacy protections. Players will be notified of any such transfer in advance.

as1131 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and our international operating licence obligations. The following retention periods apply as a general guide:

When personal data is no longer required and no legal obligation mandates its retention, as1131 will securely delete or anonymize it so that it can no longer be associated with any identifiable individual.

as1131 maintains a comprehensive information security programme designed to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Key measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your browser or device and the as1131 platform.
• AES-256 encryption at rest for sensitive data fields including KYC documents, financial records, and authentication credentials stored on our servers.
• Role-based access controls ensuring that only personnel with a specific, documented business need may access personal data in our systems.
• Multi-factor authentication (MFA) enforced for all as1131 internal administrative systems that process personal data.
• Regular penetration testing and security audits conducted by independent third-party security firms on an annual basis, with critical findings addressed within defined remediation windows.
• Data minimization practices — where possible, systems are designed to work with pseudonymized or anonymized data rather than raw personal identifiers.
• Incident response procedures to detect, contain, and notify affected players of any data breach that is likely to result in a risk to their rights or interests, within the timeframe required by applicable law.

While as1131 takes all reasonable technical and organizational measures to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your login credentials and for notifying us promptly if you suspect unauthorized access to your account.

as1131 uses cookies and similar technologies (including pixel tags and local storage) to operate and improve the platform. The types of cookies we use are described below:

You may manage your cookie preferences through your browser settings at any time. Disabling strictly necessary cookies will impair your ability to use the platform. Disabling functional or analytics cookies will not prevent you from accessing core features but may reduce platform personalization.

as1131 respects your rights as a data subject. Depending on your location and the applicable data protection framework, you may hold the following rights with respect to your personal data:

• Right of access: You may request a copy of the personal data we hold about you, together with information about how it is being used.
• Right to rectification: You may request correction of inaccurate or incomplete personal data without undue delay.
• Right to erasure: 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 retention obligations.
• Right to restrict processing: You may request that we limit the processing of your personal data in specific circumstances, for example while an accuracy dispute is being resolved.
• Right to data portability: Where processing is based on consent or contract and carried out by automated means, you may request a structured, machine-readable copy of your personal data for transfer to another service.
• Right to object: You may object at any time to processing of your personal data based on legitimate interests, including profiling for direct marketing purposes.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

To exercise any of the above rights, please contact our Data Protection Officer (DPO) using the contact details set out in Section 15 of this Policy. We will acknowledge your request within 5 business days and respond substantively within 30 calendar days. Where requests are complex or numerous, we may extend this period by a further 30 days with prior notification to you.

The as1131 platform is strictly intended for adults aged 21 years and over. We do not knowingly collect personal data from any individual under the age of 21. If we become aware that personal data has been collected from an individual under this age threshold, we will immediately suspend the associated account, delete all personal data collected, and return any deposits received.

as1131 employs age verification checks during the registration process and as part of our ongoing KYC programme to enforce this restriction. Parents and guardians who believe that a minor may have accessed the platform or submitted personal data should contact our support team immediately so that we can act without delay.

The as1131 platform may, from time to time, reference or display content from third-party game studios or payment providers. These entities operate independently and maintain their own privacy policies. as1131 is not responsible for the privacy practices or content of any third-party service, and we encourage you to review the privacy policy of any service you engage with outside the as1131 platform.

Game content delivered within the as1131 interface by providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft is subject to those studios' respective game-round data-handling practices. as1131 contractually requires all game providers to handle any session data in accordance with standards consistent with this Policy.

as1131 operates internationally and may transfer your personal data to servers or service providers located outside Indonesia. Where such transfers occur, as1131 ensures that appropriate safeguards are in place to protect your data at a standard equivalent to those described in this Policy, including:

• Binding contractual data-processing agreements incorporating internationally recognized data transfer clauses;
• Transfers to jurisdictions recognized as providing an adequate level of data protection by relevant regulatory bodies;
• Additional technical safeguards such as end-to-end encryption where data transits across borders.

You may request information about the specific safeguards applied to any cross-border transfer of your personal data by contacting our DPO at the address in Section 15.

as1131 reserves the right to update or modify this Privacy Policy at any time. When material changes are made, we will update the "Last updated" date at the top of this page and, where practicable, notify registered players via email or an in-platform notification prior to the changes taking effect.

Your continued use of the as1131 platform following the publication of any amendment constitutes acceptance of the revised Policy. If you object to any change, you should cease using the platform and contact our support team to arrange account closure. It is your responsibility to review this Policy periodically to remain informed of any updates.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact the as1131 Data Protection Officer (DPO) through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week, directly within the as1131 platform. Our support team can escalate any data protection matter to the DPO within one business day.
• Email: support at as1131 dot app — please include "Privacy Request" in the subject line. We aim to respond substantively within 30 calendar days.

Our customer support team includes Indonesian-speaking agents available across all Indonesian time zones — WIB (UTC+7), WITA (UTC+8), and WIT (UTC+9) — to ensure players across the entire archipelago receive clear, timely assistance with privacy matters.