ts138 Privacy Policy

Effective Date: January 1, 2026

This Privacy Policy describes how ts138 ("we", "us", "our", "the Operator") collects, processes, stores, and protects personal information provided by users ("you", "Player") of the ts138 online gaming platform accessible at https://ts138.cam (the "Platform"). By registering an Account or using any part of the Service, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein.

1. Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information that identifies or can reasonably be used to identify you as an individual, including your name, date of birth, email address, phone number, residential address, financial account details, and government-issued identification numbers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, and deletion.
• "Account" means the registered user profile you create on the ts138 Platform.
• "KYC" (Know Your Customer) refers to the identity verification procedures we conduct to comply with international anti-money laundering and fraud prevention standards.
• "Cookies" means small text files placed on your device by the Platform to enable certain functional and analytical capabilities.
• "Third-Party Processors" means vendors and service providers engaged by ts138 to deliver specific operational functions, such as payment processing and fraud detection.

2. Information We Collect

2.1 Information You Provide Directly

When you create an Account or interact with our Service, we collect the following categories of Personal Data:

• Identity Data: Full legal name, date of birth, gender, and nationality as stated on your government-issued ID (KTP Nasional, passport, or driver's license).
• Contact Data: Email address, phone number, and residential address in Indonesia.
• Financial Data: Bank account details for deposits and withdrawals (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon), e-wallet identifiers (OVO, DANA, GoPay, ShopeePay, LinkAja), and transaction histories associated with your Account.
• Verification Data: Copies of your government-issued identification documents, proof of address documentation, and selfie photographs submitted during the KYC verification process.
• Communications Data: Records of your interactions with our customer support team via live chat, email, WhatsApp, or in-app messaging.

2.2 Information Collected Automatically

When you visit or use the ts138 Platform, our systems automatically collect certain technical information:

• Device and Technical Data: IP address, browser type and version, operating system, device type (desktop, mobile, tablet), and screen resolution.
• Usage Data: Pages visited, games played, bets placed, features accessed, session duration, click patterns, and navigation paths through the Platform.
• Location Data: General geographic location inferred from your IP address (country and city level only — we do not use GPS or precise location tracking).
• Cookie and Tracking Data: Information collected via cookies, web beacons, and similar technologies as described in Section 8 of this Policy.

2.3 Information from Third Parties

We may receive additional information about you from third-party sources to supplement what you provide directly, including:

• Identity verification agencies used during KYC processing to confirm the authenticity of your documents.
• Payment processors who confirm transaction status, fraud scores, and account holder details for depositing and withdrawing funds.
• Responsible gaming databases maintained by international organizations that track self-exclusion requests across multiple platforms.

3. Legal Basis for Processing

ts138 processes your Personal Data on the following legal grounds:

• Contractual Necessity: Processing is required to create and manage your Account, process deposits and withdrawals, and deliver the gaming services you request.
• Legal Compliance: We are obligated to process certain data to comply with international anti-money laundering (AML) regulations, KYC requirements, and the terms of our operating license.
• Legitimate Interests: We process data where it is in our legitimate interests to do so, including fraud prevention, platform security, customer service improvement, and responsible gaming enforcement, provided these interests are not overridden by your privacy rights.
• Consent: Where we rely on your consent to process data (such as for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

4. How We Use Your Information

We use the Personal Data we collect for the following specific purposes:

• Account Administration: Creating, maintaining, securing, and closing your Account; processing your transactions; and delivering the gaming services you request on the ts138 Platform.
• Identity Verification: Conducting KYC checks to confirm your identity, age (21+ requirement), and residency status consistent with our Terms and Conditions.
• Payment Processing: Facilitating deposits to your Account via Indonesian banks and e-wallets, and processing withdrawal requests to your designated accounts.
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent transactions, unauthorized account access, money laundering, and other illegal or prohibited activities.
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behaviors, enforcing self-exclusion requests, and providing appropriate intervention and support resources.
• Customer Support: Responding to your inquiries and resolving complaints submitted through live chat, email, WhatsApp, or in-app messaging.
• Platform Improvement: Analyzing usage data in aggregate to identify technical issues, optimize platform performance, improve game recommendations, and develop new features.
• Legal Obligations: Retaining transaction records and identity documentation as required by applicable anti-money laundering laws and our operating license terms.
• Marketing Communications: Sending promotional emails, bonus notifications, and VIP program updates — but only if you have opted in to receive such communications. You may opt out at any time.

5. Data Sharing and Disclosure

5.1 Third-Party Service Providers

We share your Personal Data with carefully vetted third-party service providers who assist us in operating the Platform. These providers are contractually bound to process your data only on our instructions and in accordance with this Privacy Policy. Categories of service providers include payment processors, KYC verification agencies, fraud detection platforms, cloud infrastructure providers, and customer relationship management systems.

5.2 Legal Disclosures

We may disclose your Personal Data to law enforcement agencies, regulatory authorities, courts, or other government bodies when required to do so by law, court order, or in response to a legally valid request. We will notify you of any such disclosure where we are legally permitted to do so.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of our business assets, your Personal Data may be transferred to the acquiring entity as part of that transaction. We will notify you via email or a prominent notice on the Platform before your data is transferred and becomes subject to a different privacy policy.

5.4 What We Never Do

ts138 will never sell, rent, or trade your Personal Data to unaffiliated third parties for their own marketing or advertising purposes. We will never share your financial account details with any party not directly involved in processing your transactions.

6. Data Retention

We retain your Personal Data for as long as your Account remains active and for a period following closure as required by our legal and regulatory obligations. Specifically:

• Account and identity records are retained for a minimum of five years following account closure to satisfy anti-money laundering record-keeping requirements.
• Transaction records are retained for a minimum of five years from the date of each transaction.
• Customer support communications are retained for two years following the resolution of each case.
• Marketing data is retained until you withdraw consent or request deletion, subject to any overriding legal obligation.

Upon expiry of the applicable retention period, we will securely delete or anonymize your Personal Data so that it can no longer be associated with you.

7. Your Data Rights

As a player on the ts138 Platform, you hold the following rights with respect to your Personal Data. To exercise any of these rights, contact us using the details in Section 11.

• 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 any inaccurate or incomplete Personal Data we hold about you.
• Right to Erasure: You may request deletion of your Personal Data where there is no compelling reason for us to continue processing it, subject to our legal retention obligations.
• Right to Restriction: You may request that we restrict processing of your Personal Data in certain circumstances, such as while a dispute is pending.
• Right to Data Portability: You may request that we provide your Personal Data in a structured, machine-readable format for transfer to another service provider where technically feasible.
• Right to Object: You may object to processing of your Personal Data where we rely on legitimate interests as our legal basis, including direct marketing communications.
• Right to Withdraw Consent: Where we process your data based on consent, you may withdraw that consent at any time without affecting prior lawful processing.

We will respond to all data rights requests within 30 days of receipt. In complex cases, we may extend this period by a further 60 days with notification.

8. Cookies and Tracking Technologies

The ts138 Platform uses cookies and similar tracking technologies to provide a functional and personalized experience. Cookies are small text files stored on your device when you visit our Platform. We use the following categories of cookies:

• Essential Cookies: Required for the Platform to function correctly. These include session management, authentication, and security cookies. They cannot be disabled without impairing your ability to use the Service.
• Functional Cookies: Enable personalization features such as remembering your language preferences, display settings, and account login status between visits.
• Analytical Cookies: Help us understand how players use the Platform by collecting aggregated data on page visits, session duration, and feature usage. This data is anonymized and used solely to improve the Service.
• Security Cookies: Support fraud detection and account protection functions by identifying unusual access patterns or suspicious device fingerprints.

You may manage cookie preferences through your browser settings. Please note that disabling essential cookies may affect the functionality of the ts138 Platform.

9. Data Security

ts138 implements a comprehensive set of technical and organizational security measures to protect your Personal Data against unauthorized access, accidental loss, disclosure, alteration, or destruction. These measures include:

• Industry-standard 256-bit SSL/TLS encryption for all data transmitted between your device and our servers.
• Encrypted storage of sensitive Personal Data and financial information at rest.
• Multi-factor authentication requirements for Account access and high-value transactions.
• Regular penetration testing and security audits conducted by independent third-party security firms.
• Role-based access controls limiting employee access to Personal Data to only those with a clear operational need.
• 24/7 security monitoring and incident response procedures to detect and address threats promptly.

Despite these measures, no digital system can guarantee absolute security. In the event of a data breach that poses a risk to your rights and freedoms, we will notify affected players and relevant authorities in accordance with applicable legal requirements.

10. International Data Transfers

ts138 operates with server infrastructure and third-party service providers located in various jurisdictions. Your Personal Data may be transferred to and processed in countries outside Indonesia. Where such transfers occur, we implement appropriate safeguards — including standard contractual clauses and data processing agreements — to ensure your data receives a level of protection consistent with this Privacy Policy and applicable international data protection standards.

11. Children and Underage Players

The ts138 Platform is strictly for adults aged 21 and above. We do not knowingly collect Personal Data from individuals under the age of 21. If we discover that we have inadvertently collected data from an underage individual, we will immediately delete that data and close the associated Account. If you believe a minor has registered an Account on our Platform, please contact our support team immediately.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or operational procedures. When we make material changes, we will notify you via email to your registered address and by posting a prominent notice on the ts138 Platform. The updated Policy will include a revised effective date at the top of the document. Your continued use of the Service following notification of changes constitutes acceptance of the updated Policy.

13. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your Personal Data, please contact the ts138 Data Privacy team through any of the following channels:

• Email: [email protected]
• Live Chat: Available 24/7 on the ts138 Platform
• WhatsApp: +62 812 3456 7890

Our Indonesian-speaking customer support team is available around the clock. For formal data rights requests, please include "Data Rights Request" in the subject line of your email to ensure prompt routing to the appropriate team.