Privacy Policy

In this Privacy Policy, the following terms have the meanings set out below:

• "md108" / "Platform" / "We" / "Us" / "Our" — the md108 online gaming platform operated at https://md108.bet, including all associated subdomains, mobile interfaces, and services.
• "Member" / "You" / "Your" — any individual who has registered an account on md108 or who accesses any part of the platform.
• "Personal Data" — any information that relates to an identified or identifiable natural person; this includes your name, email address, date of birth, payment details, IP address, and any other data that can, alone or in combination with other data, be used to identify you.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, transfer, disclosure, deletion, or any combination thereof.
• "KYC" — Know Your Customer verification procedures, including identity checks, age verification, and source-of-funds documentation.
• "Cookies" — small text files placed on your device by the md108 platform to facilitate session management, analytics, and personalization features.
• "Third-Party Providers" — external organizations engaged by md108 to deliver specific services, including payment processors, game studios, and analytics providers, who may handle Personal Data on md108's behalf under contractual data-processing agreements.

md108 acts as the Data Controller for all Personal Data collected from Members and visitors to the platform. As Data Controller, md108 determines the purposes and means of Processing your Personal Data and is responsible for ensuring that all Processing activities comply with applicable data protection principles, including lawfulness, fairness, transparency, data minimization, accuracy, storage limitation, integrity, and confidentiality.

If you have any questions, concerns, or requests regarding this Privacy Policy or the Processing of your Personal Data, you may contact our dedicated Data Protection contact at any time. Contact details are provided in Section 14.

md108 collects only the Personal Data that is necessary to deliver our services safely, legally, and effectively. The categories of Personal Data we collect are described below:

md108 collects Personal Data through the following channels and mechanisms:

• Direct Submission: Data you provide voluntarily when registering an Account, completing KYC verification, making deposits or withdrawals, contacting customer support, or updating your Account profile.
• Automated Technical Collection: Data gathered automatically when you access the platform, including IP addresses, device identifiers, browser fingerprints, and session activity logs collected via server logs, cookies, and similar tracking technologies.
• Third-Party Sources: Data received from identity verification agencies, fraud prevention services, payment processors, and game providers in order to verify your identity, process transactions, and ensure platform integrity. Where permitted by law, md108 may also receive data from publicly available sources to supplement KYC records.
• Referral Programs: If you join md108 via a referral link from an existing Member, md108 may record the referral relationship for the purposes of crediting the referring Member's account with any applicable reward.

md108 processes your Personal Data for the following clearly defined purposes:

• Account Management: To register, maintain, and administer your md108 Account, including processing login sessions, tracking balances, and managing responsible gaming settings such as deposit limits and self-exclusion.
• Service Delivery: To provide access to all gaming products and services available on the platform, including sports betting, live casino, slots, and crash games, and to settle bets and pay out winnings accurately.
• Identity Verification (KYC): To verify your identity, confirm your minimum age of 21, and comply with anti-money laundering (AML) obligations by collecting and validating government-issued identification and supporting documents.
• Payment Processing: To process deposits and withdrawals via local Indonesian bank transfer and e-wallet methods, and to maintain accurate financial records of all transactions.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, multi-accounting, bonus abuse, and other security threats to the platform and its Members.
• Customer Support: To respond to inquiries, resolve disputes, process complaints, and provide technical assistance through live chat, email, and other support channels.
• Marketing Communications: To send you promotional offers, bonus announcements, and event notifications where you have given explicit consent to receive marketing communications. You may withdraw this consent at any time.
• Platform Improvement: To analyze aggregated usage data in order to improve the functionality, performance, and content of the md108 platform, including game selection, interface design, and promotional offerings.
• Legal Compliance: To fulfill md108's obligations under applicable law, including responding to lawful requests from regulatory authorities or courts of competent jurisdiction.

md108 processes your Personal Data on the following legal bases, depending on the nature and purpose of each Processing activity:

• Contractual Necessity: Processing that is necessary to perform the contract between you and md108 — including Account registration, game access, bet settlement, deposit and withdrawal processing, and customer support.
• Legal Obligation: Processing required to comply with applicable legal and regulatory obligations, including KYC identity verification, AML record-keeping, and responses to lawful authority requests.
• Legitimate Interests: Processing undertaken for the legitimate interests of md108 or third parties, where those interests are not overridden by your fundamental rights and freedoms. This includes fraud detection, platform security, abuse prevention, and internal analytics for service improvement.
• Consent: Processing based on your freely given, specific, and informed consent — in particular, the sending of direct marketing communications. Where consent is the legal basis, you have the right to withdraw it at any time without affecting the lawfulness of Processing carried out prior to withdrawal.

md108 does not sell, rent, or trade your Personal Data to any third party for their own commercial purposes. Personal Data may be shared in the following limited circumstances:

• Payment Service Providers: Personal Data necessary to process deposits and withdrawals is shared with the relevant bank or e-wallet provider (e.g., BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, LinkAja) solely for the purpose of completing the requested financial transaction.
• Identity Verification Agencies: Where required for KYC compliance, identity document details may be shared with accredited third-party verification services for the sole purpose of confirming identity and age.
• Game Studio Providers: Game studios (including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft) may receive limited technical session data necessary to deliver their games through the md108 platform. These providers are contractually prohibited from using such data for any purpose beyond game delivery.
• Fraud Prevention and Security Services: Technical and usage data may be shared with fraud detection and cybersecurity service providers engaged by md108 to protect the platform and its Members from unauthorized access and financial crime.
• Legal and Regulatory Authorities: md108 may disclose Personal Data to law enforcement, regulatory bodies, or courts of competent jurisdiction where required to do so by applicable law, valid legal process, or to protect the rights, property, or safety of md108, its Members, or the public.
• Corporate Transactions: In the event of a merger, acquisition, restructuring, or sale of all or part of md108's business, Personal Data held by md108 may be transferred to the acquiring or successor entity, subject to equivalent data protection obligations being imposed on that entity.

md108 uses cookies and similar tracking technologies to operate the platform effectively, maintain secure sessions, analyze usage patterns, and deliver a personalized experience. The types of cookies we use are as follows:

• Strictly Necessary Cookies: Essential for the platform to function. These cookies enable core features such as user authentication, session management, and security enforcement. They cannot be disabled without impairing your ability to use the platform.
• Functional Cookies: Used to remember your preferences, such as language settings, display preferences, and responsible gaming tool configurations, so that you do not need to re-enter them on each visit.
• Analytics Cookies: Used to collect aggregated, anonymized data about how Members use the platform — including pages visited, time spent on each page, and navigation paths — in order to improve platform performance and content relevance.
• Marketing Cookies: Used, where you have given consent, to track your interactions with promotional content and measure the effectiveness of md108's marketing campaigns. These cookies do not share your data with unaffiliated third-party advertisers.

You may manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will affect the functionality of the md108 platform and may prevent you from accessing certain features, including your Account.

md108 retains Personal Data only for as long as is necessary to fulfill the purpose for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention periods apply:

• Account Data: Retained for the duration of your Account's active status plus a minimum period of five (5) years following Account closure, to comply with AML record-keeping requirements and to resolve any post-closure disputes.
• Transaction Records: Financial transaction records, including deposit and withdrawal histories, are retained for a minimum of five (5) years from the date of each transaction in accordance with applicable financial record-keeping regulations.
• KYC Documents: Identity verification documents are retained for a minimum of five (5) years following the completion of KYC verification, or following Account closure, whichever is later.
• Customer Support Records: Communications and support ticket records are retained for three (3) years from the date of the most recent interaction, unless a longer period is required for an ongoing dispute or legal matter.
• Marketing Data: Marketing preference records and communication logs are retained for up to two (2) years following your last interaction with a promotional communication, or until you withdraw consent, whichever is earlier.
• Technical Logs: Server logs, IP records, and session data are retained for up to twelve (12) months for security monitoring and fraud detection purposes.

When Personal Data is no longer required for any of the above purposes, md108 will securely delete or anonymize it in accordance with industry-standard data destruction practices.

md108 implements a comprehensive set of technical and organizational security measures to protect your Personal Data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security infrastructure includes, but is not limited to:

• SSL/TLS Encryption: All data transmitted between your device and the md108 platform is encrypted using industry-standard Secure Sockets Layer (SSL) / Transport Layer Security (TLS) protocols. You can verify this by the padlock icon in your browser's address bar.
• Data Encryption at Rest: Sensitive data stored within md108's systems — including financial records and identity documents — is encrypted at rest using AES-256 or equivalent encryption standards.
• Access Controls: Access to Personal Data within md108's internal systems is restricted on a strict need-to-know basis. Staff members are granted access only to the data required to perform their specific role, and all access is logged and audited.
• Two-Factor Authentication (2FA): md108 recommends and supports two-factor authentication for Member accounts to provide an additional layer of protection against unauthorized login attempts.
• Regular Security Audits: The md108 platform undergoes regular penetration testing and security audits conducted by qualified independent security professionals to identify and remediate vulnerabilities proactively.
• Data Breach Response: In the event of a confirmed personal data breach that poses a risk to your rights and freedoms, md108 will notify affected Members without undue delay and will take all reasonable steps to contain the breach, assess its impact, and prevent recurrence.

As a Member of md108, you have the following rights with respect to your Personal Data. To exercise any of these rights, please contact us using the details in Section 14:

• Right of Access: You have the right to request a copy of the Personal Data md108 holds about you, together with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete Personal Data held about you. You may update many of your Account details directly through your profile settings.
• Right to Erasure ("Right to be Forgotten"): 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 you object to Processing and there is no overriding legitimate interest. Note that this right is subject to legal and regulatory retention obligations described in Section 9.
• Right to Restrict Processing: You may request that md108 restrict the Processing of your Personal Data in certain circumstances — for example, while the accuracy of data you have contested is being verified.
• Right to Data Portability: Where Processing is based on your consent or on contractual necessity, you have the right to receive a copy of your Personal Data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object at any time to Processing based on legitimate interests, including profiling for direct marketing purposes. Where you object to marketing Processing, md108 will cease that Processing immediately.
• Right to Withdraw Consent: Where Processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of any Processing carried out prior to withdrawal.

md108 will respond to all valid data rights requests within 30 calendar days of receipt. In complex cases, this period may be extended by a further 30 days, in which case we will notify you of the extension and its reason.

The md108 platform is strictly intended for adults aged 21 and above. md108 does not knowingly collect Personal Data from individuals under the age of 21. If you are under 21 years of age, you must not register an Account or use any part of the md108 platform.

If md108 becomes aware that it has inadvertently collected Personal Data from a person under the age of 21, we will take immediate steps to delete that data from our systems and close the associated Account. If you believe that md108 may have collected data from a minor, please notify us promptly at [email protected] so that we can investigate and take appropriate action.

md108 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, regulatory requirements, or platform functionality. When we make material changes to this Policy, we will:

• Update the "Last Updated" date at the top of this page.
• Display a prominent notice on the md108 platform informing Members of the update.
• Where the changes are significant and affect the legal basis or scope of Processing, notify active Members directly via the email address registered to their Account.

Your continued use of the md108 platform following the publication of an updated Privacy Policy constitutes your acknowledgment of the revised terms. If you do not agree with any changes, you should cease using the platform and may request closure of your Account by contacting our support team.

We recommend reviewing this Privacy Policy periodically to remain informed about how md108 handles your Personal Data. This document is written in English; in the event of any conflict between this English-language version and any translation or summary, the English version shall prevail.

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or want to report a privacy concern, please reach out to the md108 team through any of the following channels:

• Email: [email protected]
• Live Chat: Available 24/7 directly on the md108 platform
• WhatsApp: +62 811 108 0108
• Support Hours: 24 hours a day, 7 days a week — WIB (UTC+7)

When submitting a data rights request, please include your registered Account username or email address and a clear description of your request so that we can locate your records and respond efficiently. md108 may need to verify your identity before actioning certain requests to ensure that data is not disclosed or deleted without proper authorization.