Privacy Policy

1. Introduction

ship2 ("we", "us", "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our online gaming platform and services.

This Privacy Policy applies to all users who access ship2 services through our website, mobile applications, and any related platforms. By creating an account, accessing our services, or providing us with your personal information, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your information as described herein.

We are committed to compliance with applicable data protection laws including but not limited to international standards equivalent to GDPR (General Data Protection Regulation) principles, and Indonesian data protection regulations where applicable.

2. Data Controller

For the purposes of applicable data protection laws, ship2 is the data controller responsible for your personal information. Our data protection officer can be contacted at:

• Email: [email protected] (displayed as text only - contact via platform support for data requests)
• Postal Address: ship2 Data Protection Officer, [Full Company Address], [Registration Jurisdiction]
• Support Portal: Available 24/7 via ship2 account dashboard under "Privacy Settings"

If you have questions, concerns, or requests regarding your personal data, please contact us using the above channels. We aim to respond to all privacy inquiries within 30 days of receipt.

3. Information We Collect

ship2 collects various types of information to provide, maintain, and improve our services. The categories of information we collect include:

3.1 Information You Provide Directly

When you register for a ship2 account or use our services, you voluntarily provide us with personal information including:

• Account Registration Information: Full name, date of birth, email address, phone number, residential address, username, and password.
• Identity Verification (KYC) Information: Government-issued identification (KTP - Indonesian identity card), proof of address, selfie photographs for identity confirmation, and biometric data where required for enhanced security.
• Financial Information: Bank account details (BCA, BRI, BNI, Mandiri account numbers and names), e-wallet details (OVO, DANA, GoPay account information), transaction history, deposit and withdrawal records.
• Communication Information: Information you provide when contacting customer support, including chat transcripts, email correspondence, complaint details, and feedback.
• Marketing Preferences: Your consent preferences for receiving promotional communications, newsletters, and special offers.

3.2 Information Collected Automatically

When you access and use ship2 services, we automatically collect certain technical and usage information:

• Device Information: Device type, operating system, browser type and version, device identifiers (IMEI, MAC address), screen resolution, and language settings.
• Usage Information: Pages viewed, features used, games played, time spent on platform, click patterns, navigation paths, and interaction with platform elements.
• Gaming Activity: Betting history, game outcomes, wagering patterns, bonus claims, RTP (Return to Player) statistics, win/loss records, and gameplay sessions.
• Location Information: IP address, approximate geographic location derived from IP address, timezone, and internet service provider details.
• Connection Information: Connection type (WiFi, mobile data), network quality, connection timestamps, and session duration.

3.3 Information from Third Parties

We may receive information about you from third-party sources including:

• Payment Providers: Transaction confirmation data from banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay, ShopeePay).
• Identity Verification Services: Results from KYC verification checks, fraud screening results, and identity authentication confirmations.
• Game Providers: Game play statistics, RTP data, and technical game information from third-party game developers and casino platform providers.
• Marketing Partners: Attribution data showing how you discovered ship2 (referral source, campaign tracking, affiliate information).

Data Category	Purpose	Retention Period
Account Registration Data	Account creation, login authentication, user identification	Duration of account + 7 years
KYC Verification Data	Age verification, identity confirmation, regulatory compliance	Duration of account + 7 years
Financial Transaction Data	Payment processing, fraud prevention, accounting, tax compliance	7 years (legal requirement)
Gaming Activity Data	Service delivery, responsible gaming monitoring, dispute resolution	Duration of account + 2 years
Technical/Usage Data	Service improvement, security, fraud detection, analytics	2 years from collection
Marketing Preference Data	Sending promotional communications, personalized offers	Until consent withdrawn + 30 days

4. How We Use Your Information

ship2 processes your personal information for the following purposes:

4.1 Service Delivery and Account Management

• Creating and maintaining your ship2 account
• Authenticating your identity and managing login sessions
• Processing deposits and withdrawals via BCA, BRI, BNI, Mandiri, and e-wallet services
• Providing access to casino games, live dealer tables, sports betting, and other gaming products
• Processing your bets and wagers, calculating payouts, and crediting winnings
• Managing your loyalty rewards, VIP status, and tier benefits
• Providing customer support and responding to your inquiries

4.2 Regulatory Compliance and Security

• Verifying your age (21+ requirement) and confirming you meet eligibility criteria
• Conducting KYC (Know Your Customer) verification using your KTP and banking details
• Preventing fraud, money laundering, and other illegal activities
• Detecting and preventing bonus abuse, multi-accounting, and terms violations
• Complying with licensing requirements, anti-money laundering regulations, and legal obligations
• Responding to court orders, legal requests, and regulatory inquiries
• Maintaining records required by gambling regulators and financial authorities

4.3 Responsible Gaming

• Monitoring gameplay patterns to identify potential problem gambling behaviors
• Implementing deposit limits, loss limits, and session time limits you have set
• Processing self-exclusion requests and enforcing exclusion periods
• Providing reality check reminders and responsible gaming notifications
• Generating reports on your betting activity upon request
• Offering support resources and intervention when concerning patterns are detected

4.4 Service Improvement and Personalization

• Analyzing usage patterns to improve platform functionality and user experience
• Personalizing game recommendations based on your preferences and play history
• Optimizing website and mobile app performance
• Conducting research and analytics to understand player behavior and preferences
• Testing new features, games, and platform improvements
• Developing and improving our responsible gaming tools

4.5 Marketing and Communications

With your consent, we use your information to:

• Send promotional emails about new games, bonuses, and special offers
• Provide personalized bonus offers based on your gaming activity
• Send SMS notifications about exclusive promotions and tournaments
• Inform you about new features, platform updates, and service changes
• Invite you to participate in surveys and feedback sessions
• Send seasonal promotions aligned with Indonesian holidays (Idul Fitri, Ramadhan, Indonesian Independence Day, Chinese New Year)

You can opt out of marketing communications at any time by adjusting your preferences in account settings or clicking "unsubscribe" in emails.

5. Legal Basis for Processing

Under applicable data protection laws, ship2 processes your personal information based on the following legal grounds:

5.1 Contractual Necessity

We process your personal information to fulfill our contract with you under the ship2 Terms and Conditions. This includes account creation, identity verification, payment processing, game delivery, and customer support. Without this information, we cannot provide you with our services.

5.2 Legal Obligation

We are legally required to process certain personal information to comply with gambling regulations, anti-money laundering laws, tax requirements, and other applicable legislation. This includes age verification (21+ requirement), KYC verification, transaction record keeping (7-year retention), and reporting suspicious activities to authorities.

5.3 Legitimate Interests

We process personal information based on our legitimate business interests including:

• Fraud prevention and platform security
• Service improvement and platform optimization
• Business analytics and operational efficiency
• Protecting our rights and property
• Detecting and preventing terms violations

We balance these interests against your privacy rights and do not process data in ways that would be unexpected or harmful to you.

5.4 Consent

For certain processing activities, we rely on your explicit consent, particularly for:

• Marketing communications and promotional offers
• Optional data collection for personalized experiences
• Sharing data with third parties beyond what is necessary for service delivery

You can withdraw your consent at any time through your account settings. Withdrawal of consent does not affect the lawfulness of processing based on consent before withdrawal.

6. Data Sharing and Disclosure

ship2 does not sell your personal information to third parties. However, we may share your information with the following categories of recipients for specific purposes:

6.1 Service Providers

We share necessary information with third-party service providers who assist us in operating the platform:

• Payment Processors: Banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay, ShopeePay) to process deposits and withdrawals.
• Identity Verification Services: KYC verification providers who confirm your identity using your KTP and supporting documents.
• Game Providers: Third-party game developers and casino platform providers who deliver games and track gameplay.
• Cloud Hosting Providers: Companies providing server infrastructure and data storage services.
• Customer Support Tools: Live chat platforms, ticketing systems, and communication tools used to provide support.
• Analytics Providers: Services that help us understand platform usage and improve user experience.

All service providers are contractually obligated to protect your information and may only use it for the purposes we specify.

6.2 Regulatory and Legal Requirements

We may disclose your information to:

• Gambling regulatory authorities and licensing bodies
• Law enforcement agencies in response to valid legal requests
• Financial intelligence units for anti-money laundering compliance
• Courts and tribunals in response to court orders or legal proceedings
• Tax authorities for tax compliance and reporting
• Government agencies as required by applicable law

6.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the successor entity. We will notify you of any such change and provide options regarding your data.

6.4 Fraud Prevention

We may share information with fraud prevention agencies and other online gambling operators to prevent fraud, bonus abuse, and other prohibited activities. This may include sharing lists of excluded or banned users.

7. Data Security Measures

ship2 implements comprehensive technical and organizational security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction:

7.1 Technical Security Measures

• Encryption: All data transmissions use SSL/TLS encryption. Sensitive data stored in databases is encrypted at rest using AES-256 encryption.
• Access Controls: Role-based access controls ensure only authorized personnel can access personal data. Multi-factor authentication required for administrative access.
• Network Security: Firewalls, intrusion detection systems, and DDoS protection safeguard our infrastructure.
• Secure Authentication: Passwords are hashed using bcrypt with salts. We support two-factor authentication (2FA) for enhanced account security.
• Regular Security Audits: Third-party security firms conduct penetration testing and vulnerability assessments quarterly.
• Data Segregation: Player funds are kept in segregated accounts separate from operational funds.

7.2 Organizational Security Measures

• Employee Training: All staff receive data protection and security awareness training.
• Confidentiality Agreements: Employees with access to personal data sign strict confidentiality agreements.
• Data Minimization: We collect and retain only the minimum data necessary for specified purposes.
• Regular Backups: Encrypted backups are performed daily and stored in geographically separate locations.
• Incident Response Plan: We maintain a documented plan for responding to data breaches and security incidents.

7.3 Your Security Responsibilities

You also play a critical role in protecting your account:

• Choose a strong, unique password and never share it with anyone
• Enable two-factor authentication (2FA) in your account settings
• Log out after each session, especially on shared devices
• Keep your email account secure as it is used for password resets
• Report suspicious activity or unauthorized access immediately
• Be cautious of phishing attempts - ship2 will never ask for your password via email

8. Data Retention

ship2 retains your personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements.

8.1 Retention Periods by Data Type

• Account Data: Retained for the duration of your account plus 7 years after closure for regulatory compliance.
• Transaction Records: Retained for 7 years from the transaction date (legal requirement for financial records).
• KYC Documents: Retained for the duration of your account plus 7 years after closure (anti-money laundering requirement).
• Gaming Activity: Retained for the duration of your account plus 2 years for dispute resolution purposes.
• Communication Records: Retained for 3 years from the date of communication.
• Marketing Data: Retained until you withdraw consent, plus 30 days to process the withdrawal.
• Technical Logs: Retained for 2 years from collection for security and fraud prevention purposes.

8.2 Deletion Upon Request

You may request deletion of your personal information under certain circumstances (see Section 9: Your Privacy Rights). However, we may retain certain data when required by law or necessary for legitimate business purposes such as:

• Compliance with legal obligations (e.g., 7-year financial record retention)
• Resolution of ongoing disputes or legal claims
• Prevention of fraud and abuse (e.g., maintaining lists of banned users)
• Enforcement of our Terms and Conditions

When we delete data, we use secure deletion methods that render the data unrecoverable.

9. Your Privacy Rights

Under applicable data protection laws, you have the following rights regarding your personal information:

9.1 Right of Access

You have the right to request a copy of all personal information we hold about you. This includes account data, transaction history, KYC documents, gaming activity, and communication records. We will provide this information in a structured, commonly used, and machine-readable format.

9.2 Right to Rectification

If any of your personal information is inaccurate or incomplete, you have the right to request correction. You can update most information directly in your account settings, or contact support for assistance.

9.3 Right to Erasure ("Right to be Forgotten")

You may request deletion of your personal information in certain circumstances, such as when:

• The data is no longer necessary for the purposes it was collected
• You withdraw consent and there is no other legal basis for processing
• You object to processing and there are no overriding legitimate grounds
• The data has been unlawfully processed

This right is not absolute - we may retain data when required by law or for legitimate purposes as described in Section 8.2.

9.4 Right to Restriction of Processing

You can request that we temporarily limit how we use your data in certain situations, such as when you contest the accuracy of the data or object to processing.

9.5 Right to Data Portability

You have the right to receive your personal information in a structured, machine-readable format and transmit it to another data controller. This applies to data you provided to us and data processed based on consent or contract.

9.6 Right to Object

You have the right to object to:

• Processing based on legitimate interests (we will stop unless we have compelling legitimate grounds)
• Direct marketing (we will stop immediately upon request)
• Profiling for marketing purposes

9.7 Right to Withdraw Consent

Where processing is based on your consent, you can withdraw that consent at any time. This does not affect the lawfulness of processing before withdrawal.

9.8 Right to Lodge a Complaint

If you believe we have violated your privacy rights, you have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.

9.9 How to Exercise Your Rights

To exercise any of these rights, please:

• Log in to your ship2 account and navigate to "Privacy Settings"
• Submit a request via our support portal (preferred method for verification purposes)
• Email [email protected] with your request and account details

We will respond to your request within 30 days. For complex requests, we may extend this period by an additional 60 days with notification. We may request additional information to verify your identity before processing requests.

10. Cookies and Tracking Technologies

ship2 uses cookies and similar tracking technologies to enhance your experience, analyze platform usage, and deliver personalized content.

10.1 What Are Cookies?

Cookies are small text files stored on your device when you visit our website. They help us recognize your device on subsequent visits and remember your preferences.

10.2 Types of Cookies We Use

• Essential Cookies: Required for platform functionality. These enable core features like login authentication, session management, and security. You cannot opt out of these cookies.
• Performance Cookies: Collect anonymous information about how you use the platform, helping us improve performance and user experience.
• Functional Cookies: Remember your preferences and settings, such as language preference, timezone, and display options.
• Targeting/Advertising Cookies: Used to deliver personalized promotions and measure the effectiveness of marketing campaigns.

10.3 Managing Cookies

You can manage cookie preferences through your browser settings. However, disabling essential cookies may impair platform functionality. Most browsers allow you to:

• View and delete cookies
• Block all cookies
• Block third-party cookies only
• Receive notification before cookies are set

10.4 Third-Party Tracking

We use third-party analytics services (Google Analytics) to understand platform usage. These services may set their own cookies. We have configured these tools to anonymize IP addresses and respect Do Not Track signals where possible.

11. International Data Transfers

ship2 operates internationally and may transfer your personal information to countries outside Indonesia, including jurisdictions that may not provide the same level of data protection as Indonesian law.

When we transfer data internationally, we implement appropriate safeguards including:

• Standard Contractual Clauses approved by regulatory authorities
• Ensuring service providers are certified under recognized data protection frameworks
• Conducting transfer impact assessments to ensure adequate protection
• Implementing additional technical measures such as encryption

By using ship2 services, you consent to the international transfer of your information as described in this Privacy Policy.

12. Children's Privacy

ship2 services are strictly intended for adults aged 21 and older. We do not knowingly collect personal information from anyone under the age of 21.

If we discover that we have inadvertently collected information from someone under 21, we will:

• Immediately suspend the account
• Delete all associated personal information
• Refund any deposits made
• Report the incident to relevant authorities if required

If you believe we have collected information from someone under 21, please contact us immediately at [email protected].

13. Changes to This Privacy Policy

ship2 may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other operational reasons. When we make changes, we will:

• Update the "Last Updated" date at the top of this document
• Notify you via email to the address registered on your account
• Display a prominent notification on the ship2 homepage
• For material changes affecting your rights, provide at least 30 days' notice before changes take effect

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Continued use of ship2 services after changes take effect constitutes acceptance of the updated Privacy Policy.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Data Protection Officer Email: [email protected] (displayed as text - submit requests via platform support portal)
• Customer Support: Available 24/7 via live chat in your ship2 account
• Privacy Settings: Access data management tools in your account dashboard under "Privacy Settings"
• Postal Address: ship2 Data Protection Officer, [Full Company Address], [Registration Jurisdiction]

We aim to respond to all privacy inquiries within 30 days of receipt. For urgent data breach concerns or security issues, please contact our 24/7 support team immediately.