dm200m Privacy Policy

1. Introduction

dm200m ("we", "us", "our") operates the online gaming platform accessible at https://dm200m.net (the "Platform"). We are committed to protecting the privacy and personal data of every individual who visits, registers with, or otherwise interacts with the Platform ("you", "Member", "User").

This Privacy Policy describes our practices regarding the collection, use, storage, sharing, and protection of personal data. It applies to all members who have registered an account on dm200m, including residents of Indonesia and all other jurisdictions in which the Platform is accessible. This policy should be read alongside our Terms & Conditions, which govern the broader membership agreement between you and dm200m.

By registering an account or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree with any aspect of this policy, you must not use the Platform.

2. Definitions

For the purposes of this Privacy Policy, the following terms have the meanings stated:

• "Personal Data" — Any information that identifies or can reasonably be used to identify a natural person, directly or indirectly. This includes, but is not limited to, name, email address, date of birth, national identity number, bank account details, and IP address.
• "Processing" — Any operation performed on personal data, including collection, recording, storage, adaptation, retrieval, consultation, use, disclosure, erasure, or destruction.
• "Data Controller" — dm200m, the entity that determines the purposes and means of processing your personal data.
• "Data Processor" — A third party that processes personal data on behalf of dm200m under a written data processing agreement (e.g., payment processors, game studio providers, identity verification services).
• "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 and age verification process required before a Member may withdraw funds or access certain Platform features.
• "Cookie" — A small text file placed on your device by the Platform for the purposes described in Clause 10.

3. Data We Collect

dm200m collects personal data only to the extent necessary to deliver our Services securely and in compliance with applicable regulatory requirements. The categories of personal data we collect are set out below:

We do not intentionally collect special categories of sensitive personal data (such as racial or ethnic origin, religious beliefs, health data, or biometric data) unless explicitly required to meet a regulatory obligation, in which case your separate explicit consent will be sought.

4. How We Collect Data

4.1 Directly From You

The majority of personal data dm200m holds about you is provided directly by you when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or update your account preferences. You are under no obligation to provide this data, but failure to do so may prevent us from opening or maintaining your account or processing transactions.

4.2 Automatically Through the Platform

When you visit or use the Platform, we automatically collect certain technical and usage data through cookies, web beacons, server logs, and similar technologies. This data is collected regardless of whether you are logged in to your account. Please refer to Clause 10 for detailed information on our use of cookies and tracking technologies.

4.3 From Third Parties

We may receive personal data about you from the following third-party sources:

• Identity Verification Providers: Third-party KYC services that cross-reference the identity documents you provide against official databases.
• Payment Processors: Banks and e-wallet providers (such as those operating within Indonesia's national payment infrastructure) that confirm transaction details and flag potentially fraudulent activity.
• Fraud Prevention Services: Industry-standard fraud and anti-money-laundering (AML) screening tools that provide risk signals based on technical and behavioural data.
• Analytics Partners: Aggregated, anonymised data from analytics platforms used to understand Platform performance and user behaviour at a population level.

5. Purposes of Processing

dm200m processes your personal data for the following specific and legitimate purposes:

1. Account Management: To create, maintain, and administer your member account, including processing login authentication, account settings changes, and responsible gaming tool activations.
2. Identity and Age Verification: To confirm that you meet the minimum age requirement of 21 years and to verify your identity in accordance with our KYC obligations.
3. Transaction Processing: To process deposits and withdrawals in IDR via supported local Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, Bank Permata, OCBC NISP, BSI) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja), and to maintain accurate financial records.
4. Regulatory and Legal Compliance: To fulfil our obligations under applicable anti-money-laundering (AML), counter-terrorism-financing (CTF), and responsible gaming regulations, including maintaining records of transactions and player activity for the periods required by law.
5. Fraud Prevention and Security: To detect, investigate, and prevent fraudulent transactions, account takeovers, bonus abuse, and other illegal or prohibited activities on the Platform.
6. Customer Support: To respond to your support requests, resolve disputes, and maintain records of communications for quality assurance purposes.
7. Responsible Gaming: To monitor gaming behaviour and intervene proactively where patterns suggest that a Member may be experiencing harm, and to administer self-exclusion, deposit limit, and cooling-off requests.
8. Service Improvement and Analytics: To analyse aggregated usage data for the purpose of improving Platform features, optimising user experience, and developing new products.
9. Marketing Communications: To send you promotional offers, bonus notifications, and updates about Platform features — but only where you have given explicit consent to receive such communications. You may withdraw consent at any time by updating your account preferences or contacting support.

6. Legal Basis for Processing

dm200m relies on the following legal bases to process your personal data:

• Contractual Necessity: Processing required to fulfil the membership agreement between you and dm200m — including account registration, transaction processing, and customer support.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including AML/CTF obligations, KYC requirements, and regulatory reporting duties.
• Legitimate Interests: Processing carried out for purposes that serve the legitimate interests of dm200m or its members, provided those interests are not overridden by your rights and freedoms. This includes fraud prevention, platform security, and service analytics.
• Consent: Processing for purposes that are not strictly necessary for the contract or a legal obligation — most notably, direct marketing communications. Where we rely on consent, you have the right to withdraw it at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7. Sharing Your Data

dm200m shares personal data only where strictly necessary and always under appropriate safeguards. The categories of recipients are as follows:

7.1 Licensed Service Providers

We share data with carefully selected third-party processors that support the delivery of our Services, including payment gateway operators, identity verification providers, cloud hosting and infrastructure providers, and customer communication tools. All such providers are contractually bound to process data only on our instructions and to maintain standards of security equivalent to our own.

7.2 Game Studio Partners

The Platform integrates games supplied by licensed studios including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Pocket Games Soft. Certain technical data (such as session tokens and game round identifiers) is shared with these studios as necessary to deliver game functionality and resolve disputes. These studios do not receive your financial or full identity data.

7.3 Regulatory and Law Enforcement Authorities

dm200m may disclose personal data to competent regulatory authorities, law enforcement agencies, or courts where required to do so by applicable law, a binding court order, or to protect the rights, property, or safety of dm200m, its members, or the public. We will notify you of such disclosures where permitted by law.

7.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of dm200m's business, member personal data may be transferred to the acquiring entity as part of the transaction. We will provide notice of any such transfer and ensure that appropriate data protection obligations are maintained by the receiving entity.

8. Data Retention

dm200m retains personal data for as long as your account remains active and for a period thereafter as required by applicable regulatory and legal obligations. Our general retention standards are as follows:

• Active Account Data: Retained for the full duration of your membership.
• Transaction and Financial Records: Retained for a minimum of five years following the date of each transaction, in accordance with standard AML/CTF record-keeping requirements.
• KYC and Identity Documents: Retained for a minimum of five years following account closure or the completion of the relevant business relationship.
• Support Communications: Retained for up to three years following the resolution of the relevant support interaction, unless a longer period is required for an ongoing dispute or regulatory matter.
• Marketing Preference Data: Retained until you withdraw consent or request deletion, whichever is earlier, subject to any overriding legal obligation.
• Technical and Usage Logs: Retained for up to twelve months in identifiable form; thereafter retained only in aggregated and anonymised form.

When personal data is no longer required for the purposes for which it was collected, and no legal retention obligation applies, dm200m will securely delete or irreversibly anonymise that data.

9. Security Measures

dm200m employs a comprehensive suite of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Key measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the Platform is encrypted using industry-standard Transport Layer Security (TLS) protocols.
• Encrypted Data Storage: Sensitive personal data — including financial information and identity documents — is stored in encrypted form on secured servers with access restricted to authorised personnel only.
• Access Controls: Strict role-based access controls ensure that dm200m staff access personal data only on a need-to-know basis. All access is logged and subject to periodic audit.
• Two-Factor Authentication (2FA): Available to all Members for login security and strongly recommended. Internal administrative systems also require 2FA for all staff.
• Penetration Testing and Vulnerability Management: The Platform undergoes regular independent security assessments to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: dm200m maintains a documented data breach response procedure. In the event of a security incident that poses a material risk to your rights, we will notify affected Members and relevant authorities within the timeframes required by applicable law.

While dm200m takes every reasonable precaution to protect your data, no online platform can guarantee absolute security. You play an important role in protecting your own account by keeping your login credentials confidential and enabling 2FA.

10. Cookies & Tracking Technologies

10.1 What Are Cookies?

Cookies are small text files placed on your device when you visit the Platform. They allow us to recognise your browser, remember your preferences, and gather information about how the Platform is used. We also use similar technologies including web beacons, pixel tags, and local storage objects.

10.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in during your visit. You cannot opt out of these without ceasing to use the Platform.
• Functional Cookies: Remember your preferences, such as language settings and responsible gaming limit configurations, to provide a consistent experience across sessions.
• Analytics Cookies: Collect anonymised data about how Members navigate the Platform — which pages are visited most, where users drop off, and how long sessions last. This helps us improve the user experience. We use only reputable, privacy-compliant analytics services.
• Security Cookies: Used to detect and prevent fraudulent activity, including cross-site request forgery (CSRF) protection and bot-detection mechanisms.

10.3 Managing Cookies

You can control and delete cookies through your browser settings. Most modern browsers allow you to block or delete cookies entirely, or to prompt you before a cookie is set. Please note that disabling strictly necessary cookies will impair your ability to use the Platform. Instructions for managing cookies in common browsers are available through their respective help documentation.

11. Your Rights

As a Member of dm200m, you have the following rights with respect to your personal data. To exercise any of these rights, contact our support team at [email protected]. We will acknowledge your request within 72 hours and provide a substantive response within 30 days.

Please note that certain rights may be limited where exercising them would conflict with dm200m's legal obligations — for example, we cannot delete financial records that we are required by law to retain.

12. Minors

The dm200m Platform is strictly restricted to individuals aged 21 years and over. We do not knowingly collect personal data from anyone under the age of 21. Age verification is conducted as part of the KYC process for all Members. If dm200m discovers or is informed that personal data belonging to a person under the age of 21 has been collected, that data will be deleted immediately and the associated account will be closed without notice. 21+

If you are a parent or guardian and believe that a minor has provided personal data to dm200m, please contact us immediately at [email protected] and we will take prompt remedial action.

13. International Data Transfers

dm200m is an internationally operated platform. Your personal data may be transferred to and processed in countries outside Indonesia, including the jurisdiction in which dm200m's servers or third-party processors are located. Where such transfers occur, dm200m ensures that appropriate safeguards are in place to protect your data to a standard at least equivalent to that required under the data protection principles applied in this policy.

Safeguards may include standard contractual clauses incorporated into agreements with data processors, adherence to internationally recognised privacy frameworks, or transfers to jurisdictions that have been assessed as providing an adequate level of data protection. By using the Platform, you consent to such transfers on the terms described in this clause.

14. Changes to This Privacy Policy

dm200m reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, we will notify you by displaying a prominent notice on the Platform upon your next login and, where appropriate, by sending an email to your registered address.

The "Last updated" date at the top of this page indicates when the current version of the policy took effect. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not accept the revised terms, you should cease using the Platform and may request account closure in accordance with Clause 11.

15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by dm200m, please reach out to us through any of the following channels:

• Live Chat: Available within your member account, 24 hours a day, 7 days a week for immediate assistance.
• Indonesian-Speaking Support Agents: On duty daily between 08:00 and 24:00 WIB to assist members in both English and Indonesian.
• Email: [email protected] — please include "Privacy Request" in the subject line for efficient routing. Do not click this address; it is displayed as plain text only.

dm200m targets a 72-hour acknowledgement window for all written privacy requests and aims to provide a full substantive response within 30 calendar days.