About This Policy

This Privacy Policy ("Policy") describes how cumi88 ("we", "us", "our", "Platform") collects, processes, stores, and protects personal data provided by or generated by individuals ("you", "Player", "User") who access or use the cumi88 platform at https://cumi88.cam. By registering an account or using any service on cumi88, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. This Policy forms part of your overall agreement with cumi88 and should be read alongside the Terms & Conditions.

1. Definitions

The following definitions apply throughout this Policy:

Term Meaning
"Personal Data" Any information that identifies or could reasonably be used to identify a natural person, including name, email address, date of birth, device identifiers, and financial account details.
"Processing" Any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure, or destruction.
"Data Controller" cumi88, the entity that determines the purposes and means of processing Personal Data collected through the Platform.
"Data Processor" Any third-party service provider that processes Personal Data on behalf of cumi88 under a contractual data-processing agreement.
"Cookies" Small text files placed on a User's device by the Platform to enable session management, preferences, and analytics.
"KYC" Know Your Customer — the identity and document verification process required by international AML and CTF compliance standards.

2. Personal Data We Collect

cumi88 collects only the personal data that is necessary to provide our services, comply with legal obligations, and maintain the security and integrity of the Platform. The categories of personal data we collect are as follows:

Identity Data

Full legal name, date of birth, nationality, government-issued ID number, and photographic identity documents submitted during KYC verification.

Contact Data

Email address, mobile phone number, and residential address in Indonesia or other country of residence provided at registration.

Financial Data

Indonesian bank account details (BCA, BRI, BNI, Mandiri, CIMB Niaga, BSI, etc.), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja), deposit and withdrawal records, and transaction history.

Gaming Data

Betting history, game session logs, wager amounts, game preferences, bonus usage records, and responsible gaming settings such as deposit limits and self-exclusion periods.

Technical Data

IP address, device type and model, operating system, browser type and version, time zone, screen resolution, and session timestamps.

Communications Data

Records of your interactions with our customer support team via live chat, email, WhatsApp, and Telegram, including message content and response history.

Usage Data

Clickstream data, pages visited, navigation paths, referral sources, promotional links clicked, and time spent on specific sections of the Platform.

Location Data

Approximate geographic location inferred from your IP address, used for compliance screening and to detect access from restricted jurisdictions.

We do not collect or process sensitive special-category data such as racial or ethnic origin, religious beliefs, health records, or political opinions. We do not collect data from social media profiles without your explicit consent.

3. How We Collect Your Data

cumi88 collects personal data through the following channels:

  • Direct Submission: Data you actively provide when creating an account, completing the KYC verification process, making deposits or withdrawals, requesting bonuses, or contacting customer support.
  • Automated Collection: Data generated automatically by your use of the Platform, including IP addresses, device identifiers, session logs, and cookie data collected by our analytics and security infrastructure.
  • Payment Partners: Transaction confirmation data received from Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja) in connection with deposit and withdrawal processing.
  • Identity Verification Partners: Responses from third-party KYC and AML screening services used to verify your identity and check against international sanctions and politically exposed persons (PEP) lists.
  • Fraud Prevention Systems: Risk signals and device fingerprinting data from our fraud detection infrastructure to protect the Platform and all Players from unauthorised access and financial crime.

4. Purpose of Processing

cumi88 processes personal data for the following clearly defined purposes:

  • Account Management: To create, maintain, and administer your Player Account, including managing your profile, preferences, login credentials, and account security settings.
  • Service Delivery: To provide access to all Platform features including the sportsbook, live casino, slots, and promotional offerings, and to personalise your gaming experience based on your history and preferences.
  • Financial Transactions: To process deposits and withdrawals through your nominated Indonesian bank accounts and e-wallets, verify transaction legitimacy, and maintain accurate financial records.
  • Identity Verification (KYC): To verify your identity and age in compliance with international Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) standards before activating full account functionality or processing withdrawals.
  • Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, multi-accounting, bonus abuse, money laundering, and unauthorised access to Accounts.
  • Responsible Gaming: To monitor gaming patterns for signs of problem gambling, enforce self-exclusion and deposit limits requested by Players, and deliver responsible gaming communications and resources.
  • Customer Support: To respond to enquiries, resolve disputes, process complaints, and improve the quality of our support services.
  • Marketing Communications: To send you promotional offers, bonus notifications, and seasonal campaigns relevant to your gaming interests, where you have not opted out of such communications.
  • Legal and Regulatory Compliance: To fulfil obligations under applicable law, respond to lawful requests from competent authorities, and maintain records required for audit and regulatory purposes.
  • Platform Improvement: To analyse usage patterns, conduct A/B testing, identify technical issues, and develop new features and services that better serve our Player community.

6. Data Sharing & Disclosure

cumi88 does not sell, rent, or trade your personal data to any third party for their own marketing purposes. We share personal data only in the following limited circumstances and only to the extent strictly necessary:

  • Payment Service Providers: Indonesian banks and e-wallet operators (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, OVO, DANA, GoPay, ShopeePay, LinkAja) receive the minimum financial data required to process your transactions securely.
  • KYC and AML Partners: Accredited identity verification and sanctions-screening providers receive identity documents and personal identifiers solely for the purpose of completing your KYC verification and ongoing AML compliance monitoring.
  • Game Studio Providers: Licensed game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft receive anonymised session data necessary to deliver their game content through the Platform. These providers do not receive your full identity or financial data.
  • Technology and Infrastructure Partners: Cloud hosting, cybersecurity, and platform analytics providers who process data on our behalf under contractual data-processing agreements that bind them to confidentiality and security obligations equivalent to those described in this Policy.
  • Fraud Prevention Networks: Industry-wide fraud intelligence platforms may receive hashed or anonymised device and behavioural signals to protect the broader online gaming ecosystem from organised fraud.
  • Legal and Regulatory Authorities: Competent courts, law enforcement agencies, and financial regulators may receive personal data where cumi88 is required to disclose it by law, court order, or binding regulatory directive. We will notify you of such disclosures where legally permitted to do so.
  • Business Transfers: In the event of a merger, acquisition, or sale of all or part of cumi88's business, personal data may be transferred to the acquiring entity, subject to equivalent privacy protections and advance notice to affected Players.
Our Data-Sharing Commitment

Every third party that receives personal data from cumi88 is bound by a written agreement requiring them to process that data only for the specified purpose, apply industry-standard security controls, and comply with applicable data protection law. We conduct periodic reviews of our third-party data processors to ensure ongoing compliance.

7. Cookies & Tracking Technologies

cumi88 uses cookies and similar tracking technologies to ensure the Platform functions correctly, to remember your preferences, and to gather analytics that help us improve our services. The cookies we use fall into the following categories:

  • Strictly Necessary Cookies: Essential for core Platform functionality, including maintaining your login session, remembering your account preferences, and enabling secure payment flows. These cookies cannot be disabled without affecting core service delivery.
  • Performance and Analytics Cookies: Used to measure Platform traffic, identify popular pages, track session durations, and analyse user journeys. This data is aggregated and anonymised and does not identify individual Players.
  • Functional Cookies: Used to remember language preferences, display settings, and game history for a more personalised experience on your next visit.
  • Marketing and Targeting Cookies: Used, where you have provided consent, to deliver promotional content relevant to your gaming interests and to measure the effectiveness of our marketing campaigns.

You may manage your cookie preferences through your browser settings at any time. Disabling non-essential cookies will not prevent you from accessing core Platform features, though some personalisation functionality may be reduced. For consent-based cookies, you may withdraw consent by contacting our support team.

8. Data Retention

cumi88 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected or as required by applicable law and regulatory standards. Our standard retention periods are as follows:

  • Active Account Data: Retained for the full duration of your account relationship with cumi88 plus a minimum of five (5) years following permanent account closure, in compliance with international AML record-keeping requirements.
  • KYC and Identity Documents: Retained for a minimum of five (5) years from the date of submission or from the date of account closure, whichever is later, in accordance with AML and CTF regulatory obligations.
  • Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction to support financial audit trails and regulatory reporting obligations.
  • Customer Support Communications: Retained for three (3) years from the date of the last interaction, to support dispute resolution and quality assurance processes.
  • Marketing Preferences and Consent Records: Retained for the duration of your active account, plus two (2) years following opt-out or account closure, to demonstrate compliance with consent obligations.
  • Technical and Usage Logs: Retained for thirteen (13) months on a rolling basis, after which they are permanently anonymised or deleted.

Once the applicable retention period expires, personal data is securely deleted or irreversibly anonymised using methods that prevent any possibility of re-identification. Anonymised aggregated data may be retained indefinitely for statistical analysis and platform improvement purposes.

9. Data Security

cumi88 takes the security of your personal data seriously and applies multiple layers of technical and organisational safeguards to protect it against unauthorised access, loss, alteration, or disclosure. Our security measures include:

  • SSL/TLS Encryption: All data transmitted between your browser or device and the cumi88 Platform is encrypted using industry-standard Transport Layer Security (TLS) protocols, indicated by the HTTPS padlock in your browser.
  • Encryption at Rest: Sensitive personal data, including identity documents and financial account details, is stored in encrypted form using AES-256 encryption on secured servers.
  • Access Controls: Access to personal data within cumi88's internal systems is restricted on a strict need-to-know basis. All staff with data access undergo background checks, confidentiality training, and are bound by data protection obligations.
  • Two-Factor Authentication (2FA): Players are strongly encouraged to enable 2FA on their accounts. cumi88 supports authenticator-based 2FA to add an additional layer of account security beyond the password.
  • Fraud Detection Systems: Real-time monitoring systems analyse transaction patterns and login behaviour to detect and respond to suspicious activity automatically and promptly.
  • Regular Security Audits: cumi88 conducts periodic penetration testing, vulnerability assessments, and third-party security audits to identify and remediate potential weaknesses in our infrastructure.
  • Data Breach Response: In the event of a confirmed data breach that is likely to result in significant harm to Players, cumi88 will notify affected individuals and relevant authorities within the timeframes required by applicable law.
Your Responsibility

While cumi88 applies robust security measures on the Platform side, you are responsible for keeping your login credentials confidential and for using a strong, unique password for your account. cumi88 will never contact you by email, chat, or phone to request your password. If you receive such a request, treat it as a phishing attempt and report it to [email protected] immediately.

10. Your Data Rights

cumi88 respects your rights in relation to your personal data. Subject to applicable law and certain regulatory limitations (such as AML record-keeping obligations that may prevent immediate deletion), you have the following rights:

Right of Access

Request a copy of the personal data we hold about you and details of how it is being processed.

Right of Rectification

Request correction of any inaccurate or incomplete personal data held in your Account.

Right to Erasure

Request deletion of your personal data where it is no longer necessary, subject to legal retention obligations.

Right to Restrict Processing

Request that we limit how we use your data in certain circumstances, such as while a dispute is under review.

Right to Portability

Request a structured, machine-readable copy of data you have provided to us for transfer to another service.

Right to Object

Object to processing based on legitimate interests or for direct marketing purposes, effective immediately on receipt.

Right to Withdraw Consent

Withdraw previously given consent for marketing or non-essential cookies at any time without affecting prior lawful processing.

Right to Complain

Lodge a complaint with a relevant supervisory authority if you believe your data rights have been infringed.

To exercise any of the above rights, please submit a written request to [email protected] with the subject line "Data Rights Request". We will acknowledge your request within 72 hours and provide a substantive response within 30 days. Where requests are complex or numerous, we may extend this period by an additional 30 days with prior notification.

11. International Data Transfers

11.1 cumi88's servers and operational infrastructure are distributed across multiple geographic locations to ensure Platform reliability and performance. As a result, your personal data may be transferred to, and processed in, countries outside Indonesia.

11.2 Where personal data is transferred internationally, cumi88 ensures that adequate safeguards are in place, including contractual data protection clauses modelled on internationally recognised standards, binding corporate rules where applicable, and transfers only to jurisdictions or service providers that meet equivalent data protection standards.

11.3 By using the cumi88 Platform, you acknowledge and consent to the international transfer of your personal data as described in this section, subject to the safeguards outlined above.

12. Minors and Age Restriction

cumi88 is strictly an adults-only platform. We do not knowingly collect personal data from individuals under 21 years of age. Our registration process requires users to confirm they are 21 or older, and we conduct age verification as part of our KYC process.

If we discover that personal data has been collected from an individual under the age of 21, we will immediately close the associated account, delete all personal data collected from that individual, and take all appropriate steps required under applicable law, including reporting to relevant authorities where mandated.

If you believe a minor has registered an account on cumi88, please contact us immediately at [email protected] so we can investigate and act accordingly.

13. Changes to This Privacy Policy

13.1 cumi88 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, service offerings, applicable law, or regulatory guidance. All revisions will be published on this page with an updated "Last Updated" date at the top.

13.2 Where changes are material — meaning they significantly affect how we process your personal data or your rights in relation to it — we will provide advance notice via email to your registered address or through a prominent on-site notice at least 14 days before the changes take effect.

13.3 Your continued use of the Platform following the effective date of any revision constitutes your acceptance of the updated Policy. If you do not accept the revised terms, you must cease using the Platform and contact support to close your account and arrange withdrawal of any remaining balance.

14. Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise your data rights, or want to raise a concern about how your personal data has been handled, please contact the cumi88 data protection team using the details below:

Data Protection Contact

Email: [email protected]

Subject Line: "Privacy Enquiry" or "Data Rights Request"

Our team is available 24 hours a day, 7 days a week. All privacy-related enquiries are handled by designated staff with data protection responsibilities. We aim to acknowledge all privacy requests within 72 hours and resolve them fully within 30 days.

If you are not satisfied with our response to a privacy complaint, you have the right to escalate your concern to a relevant data protection supervisory authority in your jurisdiction. cumi88 is committed to cooperating with supervisory authorities to resolve any unresolved complaints.

How cumi88 Protects Your Privacy

End-to-End Encryption

Every byte of data exchanged between your device and the cumi88 Platform is protected by TLS 1.3 encryption. Sensitive stored data, including identity documents and payment details, is encrypted at rest using AES-256 — the same standard used by international financial institutions.

Rigorous KYC Standards

Our identity verification process protects both the Platform and every legitimate Player. By verifying who each Player is, we prevent fraud, money laundering, and underage access — ensuring a safe environment for all members of the cumi88 community across Indonesia.

Zero Data Selling

cumi88 has never sold, rented, or exchanged Player personal data with third-party marketers. Your information is used exclusively to operate our platform, process your transactions, and comply with legal obligations. Your data is not a commercial product.

Player-Controlled Preferences

You remain in control of your communication preferences and cookie settings at all times. Opt out of marketing emails, manage cookie consent, or submit a full data erasure request — all handled by our dedicated support team within 30 days.

Vetted Third Parties Only

Every payment partner, game studio, and technology provider that touches cumi88 Player data is contractually bound to the same data protection standards we apply internally. We conduct periodic compliance reviews of all third-party processors to ensure ongoing adherence.

Defined Retention Periods

We do not keep your data indefinitely. Clear, documented retention schedules govern every data category we process. When the retention period expires, data is securely and permanently deleted — not archived, not re-purposed, not passed on.

Have Questions About Your Data?

Our support team is available around the clock to address any privacy concerns, data rights requests, or general enquiries about how cumi88 handles your personal information.