Privacy Policy

1 Introduction

nusagg operates as an internationally licensed online betting and gaming platform, primarily serving players in Indonesia. We are committed to handling your personal data with the highest standards of confidentiality, integrity, and transparency. This Privacy Policy has been drafted in accordance with internationally recognised data protection principles, including those reflected in the General Data Protection Regulation (GDPR) framework, and adapted to serve our Indonesian player base.

Throughout this Policy, references to "nusagg", "we", "us", or "our" mean the nusagg platform and its data-processing operations. References to "you", "your", or "Player" mean any individual who registers an account on, visits, or interacts with nusagg through any channel, including the website nusagg.cam, mobile browsers, and any other interface we make available.

We process personal data only where we have a lawful basis to do so, and only to the extent necessary for the purposes described in this Policy. We do not sell your personal data to third parties for their own marketing purposes.

2 Definitions

• "Personal Data" — any information that identifies or can reasonably identify a living individual, including name, email address, phone number, national ID number, IP address, device identifiers, and financial account details.
• "Processing" — any operation performed on personal data, including collection, storage, use, disclosure, deletion, or any other form of handling.
• "Data Controller" — nusagg, in its capacity as the entity that determines the purposes and means by which your personal data is processed.
• "Data Processor" — a third party that processes personal data on nusagg's behalf and under nusagg's documented instructions.
• "Consent" — a freely given, specific, informed, and unambiguous indication of your agreement to the processing of your personal data for a stated purpose.
• "KYC" — Know Your Customer; the identity verification and age-check process that nusagg is obligated to perform for anti-money-laundering compliance.
• "Cookies" — small text files placed on your device when you visit nusagg, which allow us to recognise your browser and store certain information about your preferences and session.
• "Platform" — the nusagg website and any associated interfaces through which our Services are delivered.

3 Data We Collect

nusagg collects personal data in the following categories:

3.1 Identity Data

• Full legal name as it appears on your National Identity Card (KTP)
• Date of birth and age (verified as 21+)
• KTP number (Indonesian national identification number)
• Selfie photographs and KTP image submitted for KYC verification

3.2 Contact Data

• Email address
• Mobile phone number (Indonesian format, e.g., 08xx)
• Residential address (collected for enhanced KYC on high-value withdrawals)

3.3 Financial Data

• Bank account numbers (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Permata, and others)
• E-wallet account identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja)
• Transaction history: deposit amounts, withdrawal amounts, dates, and references in IDR (Rp)
• Bonus usage, wagering activity, and balance history

3.4 Technical Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser version
• Session timestamps, login history, and page interaction logs
• Cookies and similar tracking identifiers (see Section 12)

3.5 Behavioural & Gaming Data

• Betting and gaming activity: game types played, wager sizes, win/loss records
• Responsible gaming tool usage: deposit limits set, cooling-off periods activated, self-exclusion requests
• Customer support interactions: chat transcripts, email exchanges, and call records (where applicable)

4 How We Collect Data

nusagg collects your personal data through the following mechanisms:

• Direct collection: information you provide during account registration, KYC submission, deposit/withdrawal requests, support interactions, and promotional opt-ins.
• Automated collection: technical data gathered automatically when you access the Platform, including browser cookies, server logs, and analytics scripts.
• Third-party sources: identity verification partners and payment processors may share verification or transaction outcomes with us to fulfil KYC and AML obligations.
• Fraud and AML monitoring tools: we may receive risk-score or flagging data from third-party fraud detection services integrated into our payment pipeline.

5 Purposes of Processing

We process your personal data only for clearly defined and legitimate purposes. The table below summarises each processing purpose alongside the type of data involved:

6 Legal Basis for Processing

nusagg processes your personal data on one or more of the following legal bases:

• Performance of contract: processing necessary to provide the services you have requested, including account management, deposits, withdrawals, and gaming services.
• Legal obligation: processing required to comply with KYC/AML regulations, age verification laws, financial reporting obligations, and other legal duties imposed on us as a licensed operator.
• Legitimate interests: processing necessary for fraud prevention, platform security, responsible gaming interventions, analytics, and operational improvement, provided such processing does not override your fundamental rights.
• Consent: processing for which you have given explicit consent, such as receiving promotional emails, SMS marketing, or personalised offers. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Where we rely on legitimate interests as the legal basis, we have conducted a balancing assessment to ensure that our interests do not unfairly infringe upon your privacy rights.

7 Data Sharing & Third-Party Disclosure

nusagg does not sell your personal data. However, we may share your data with carefully selected third parties under strict contractual safeguards:

7.1 Payment Processors

We share financial and identity data with payment service providers (banks and e-wallet platforms such as BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, LinkAja) solely to process your deposit and withdrawal transactions.

7.2 KYC & Identity Verification Partners

We share your KTP, selfie, and personal details with third-party identity verification services to fulfil our KYC obligations and verify that you are 21 years or older.

7.3 Game Providers

Your gaming activity and pseudonymised player identifiers may be shared with third-party game studios (e.g., Pragmatic Play, Evolution Gaming, NetEnt, Microgaming) to deliver live casino and slot game services.

7.4 Fraud & AML Monitoring Services

We share transaction and behavioural data with fraud-detection and AML-compliance platforms to identify suspicious activity and protect the integrity of the Platform.

7.5 Legal & Regulatory Authorities

We will disclose personal data to law enforcement, courts, regulatory bodies, or government agencies where required by law, court order, or legitimate request, or where necessary to protect our legal rights, prevent fraud, or ensure player safety.

7.6 Professional Advisors

We may share data with legal counsel, auditors, accountants, and compliance consultants under strict confidentiality agreements, where such disclosure is necessary for professional advice or regulatory compliance.

8 International Data Transfers

nusagg operates an internationally licensed platform, and certain personal data may be transferred to, stored in, or processed in jurisdictions outside Indonesia. This includes transfers to our hosting providers, game studio servers, and payment processing partners located in various countries.

Where we transfer your data internationally, we ensure that:

• The recipient country is recognised as providing an adequate level of data protection, or
• We have entered into Standard Contractual Clauses (SCCs) or equivalent safeguards with the data recipient, or
• The transfer is necessary for the performance of our contract with you (e.g., processing a withdrawal through an international payment gateway).

You may contact our Data Protection Officer (see Section 16) to obtain further information about the safeguards we have in place for international transfers.

9 Data Retention

nusagg retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. The following retention periods apply:

• Account data (active accounts): retained for the duration of your account lifetime plus seven (7) years after account closure, in accordance with financial record-keeping and AML obligations.
• KYC documents: retained for seven (7) years from the date of verification, as mandated by international AML regulations.
• Transaction records: retained for seven (7) years from the transaction date, to comply with tax, audit, and financial reporting obligations.
• Marketing consent records: retained until consent is withdrawn, after which the record of consent itself is retained for three (3) years as proof of lawful processing.
• Technical and session logs: retained for ninety (90) days for security and fraud-detection purposes, then anonymised or deleted.
• Support and communication records: retained for three (3) years to manage disputes and improve service quality.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that you can no longer be identified from it.

10 Security Measures

nusagg employs industry-standard technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or damage. Our security framework includes:

• 256-bit SSL/TLS encryption: all data transmitted between your device and our servers is encrypted using the highest commercially available encryption standards.
• Secure data storage: personal data is stored on encrypted servers located in secure, access-controlled data centres.
• Access controls: access to personal data is restricted to authorised personnel only, based on role-based access control (RBAC) and the principle of least privilege.
• Multi-factor authentication (MFA): critical systems and admin accounts require multi-factor authentication to prevent unauthorised access.
• Regular security audits: our platform undergoes periodic penetration testing, vulnerability scanning, and independent security audits.
• Employee training: all staff with access to personal data receive mandatory data protection and security training.
• Incident response plan: we maintain a documented data breach response procedure to ensure prompt detection, containment, and notification in the event of a security incident.

11 Your Data Protection Rights

Under applicable data protection laws and nusagg's commitment to transparency, you have the following rights regarding your personal data:

• Right of access: you may request a copy of the personal data we hold about you, along with information about how it is processed.
• Right to rectification: you may request correction of inaccurate or incomplete personal data.
• Right to erasure ("right to be forgotten"): you may request deletion of your personal data where there is no legal obligation to retain it, subject to financial record-keeping and AML retention periods.
• Right to restriction of processing: you may request that we suspend processing of your data in certain circumstances, such as while we verify its accuracy or assess a legal claim.
• Right to data portability: you may request a copy of your data in a structured, machine-readable format to transfer to another service provider.
• Right to object: you may object to processing based on legitimate interests or for direct marketing purposes. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your rights.
• Right to withdraw consent: where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
• Right to lodge a complaint: if you believe we have not handled your data lawfully, you have the right to lodge a complaint with a supervisory data protection authority in your jurisdiction.

To exercise any of these rights, please contact our Data Protection Officer using the contact details in Section 16. We will respond to your request within thirty (30) days, or inform you if an extension is necessary.

12 Cookies Policy

nusagg uses cookies and similar tracking technologies to enhance your experience, analyse platform usage, and deliver personalised content. A cookie is a small text file stored on your device that allows us to recognise your browser on subsequent visits.

12.1 Types of Cookies We Use

• Essential cookies: necessary for the Platform to function, including session management, load balancing, and security features. These cannot be disabled.
• Functional cookies: remember your preferences (e.g., language, currency display) and provide enhanced features.
• Analytics cookies: collect aggregated data about how visitors use the Platform, helping us improve performance and user experience. We use tools such as Google Analytics for this purpose.
• Marketing cookies: track your activity across websites to deliver targeted advertisements and measure campaign effectiveness. These require your consent.

12.2 Managing Cookies

You can manage cookie preferences through your browser settings. Disabling essential cookies may affect the functionality of the Platform. Disabling analytics or marketing cookies will not impair core services but may result in a less personalised experience.

For more information on managing cookies, please visit your browser's help documentation or visit www.allaboutcookies.org (reference only; we do not control external sites).

13 Protection of Minors

nusagg is strictly for individuals aged 21 years or older. We do not knowingly collect, process, or retain personal data from anyone under the age of 21. All users are required to confirm their age during registration, and we verify age through mandatory KYC.

If we discover that we have inadvertently collected data from a person under 21, we will immediately delete that data and permanently close the associated account. If you believe we have collected data from a minor, please contact us immediately at [email protected].

14 Third-Party Links & External Sites

The nusagg platform may contain links to third-party websites, such as payment processor portals, game studio sites, or responsible gaming resources. nusagg is not responsible for the privacy practices or content of these external sites.

We encourage you to review the privacy policies of any third-party site you visit. This Privacy Policy applies solely to data collected by nusagg through the nusagg.cam domain and associated interfaces.

15 Policy Amendments

nusagg reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or service offerings. Material changes will be communicated to you via email and/or a prominent notice on the Platform at least fourteen (14) days before the revised Policy takes effect.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. Continued use of the Platform after the effective date of any changes constitutes your acceptance of the revised Policy.

16 Contact Us & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, or if you wish to exercise any of your data protection rights, please contact our Data Protection Officer (DPO):

• Email: [email protected] (plain-text address — this is not a clickable link)
• Subject Line: Please use "Data Protection Request" or "Privacy Inquiry" for faster routing
• Response Time: We aim to respond to all privacy-related inquiries within thirty (30) days

Our DPO is responsible for overseeing compliance with this Privacy Policy and applicable data protection laws, and serves as your primary point of contact for all privacy matters.