Privacy Policy — p2000m

1.1 p2000m ("we", "us", "our") is committed to protecting the privacy and security of your personal data. This Privacy Policy describes how we collect, use, disclose, and safeguard information we obtain from users ("Members", "you", "your") of the p2000m Platform accessible at https://p2000m.cam.

1.2 By creating an Account on p2000m, accessing the Platform, or using any of our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal data as described herein.

1.3 This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern your use of the Platform and form part of the binding legal agreement between you and p2000m.

2.1 For the purposes of applicable data protection laws, p2000m acts as the data controller responsible for the personal data you provide to us through the Platform.

2.2 Our Data Protection Officer can be contacted at [email protected] for any questions, concerns, or requests relating to how we handle your personal data.

2.3 p2000m is licensed and regulated internationally and operates in compliance with internationally recognized data protection standards including principles derived from the EU General Data Protection Regulation (GDPR), which we apply as best practice regardless of jurisdiction.

3.1 p2000m collects the following categories of personal data from Members:

3.2 Sources of Data. We collect personal data directly from you when you register an Account, submit KYC documents, make deposits or withdrawals, place wagers, contact support, or interact with the Platform. We also collect data automatically through cookies and similar tracking technologies as described in Clause 10.

3.3 Sensitive Personal Data. We do not intentionally collect or process sensitive personal data (such as health information, political opinions, religious beliefs, or biometric data) except where strictly necessary for identity verification (e.g., facial recognition matching on a photo ID) and with your explicit consent.

4.1 p2000m processes your personal data for the following purposes:

• Account Management: To create and maintain your Member Account, authenticate your identity, and provide access to the Platform.
• Service Delivery: To process deposits and withdrawals, manage your account balance, settle bets, award bonuses, and deliver the core betting and gaming services you have requested.
• KYC and Compliance: To verify your identity and age (21+ requirement), comply with anti-money-laundering (AML) regulations, prevent fraud, detect and investigate suspicious transactions, and fulfill our legal obligations as a regulated operator.
• Customer Support: To respond to your inquiries, resolve technical issues, handle complaints, and provide assistance in English or Indonesian as requested.
• Security and Fraud Prevention: To monitor Account activity for irregular betting patterns, collusion, bonus abuse, unauthorized access, or other prohibited conduct; to protect the integrity of the Platform and safeguard Member funds.
• Platform Improvement: To analyze usage patterns, identify popular games and markets, optimize site performance, test new features, and enhance the overall user experience.
• Marketing and Promotions: To send you promotional emails, bonus offers, tournament invitations, and personalized recommendations based on your betting preferences, but only if you have opted in to receive such communications.
• Legal Compliance: To respond to legal requests from law enforcement or regulatory authorities, enforce our Terms & Conditions, and comply with applicable gambling, tax, and data protection laws.
• Research and Analytics: To generate aggregated, anonymized statistics and reports for business intelligence purposes, market research, and regulatory reporting (aggregated data does not identify individual Members).

4.2 We process your personal data only for the specific purposes stated above and will not use it for any purpose incompatible with those purposes without obtaining your prior consent.

5.1 Under applicable data protection laws, p2000m must have a valid legal basis for processing your personal data. We rely on the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you (the Terms & Conditions) — for example, to process deposits, settle bets, and manage your Account.
• Legal Obligation: Processing is necessary to comply with legal obligations imposed on p2000m, such as KYC verification, AML checks, tax reporting, and responding to lawful requests from authorities.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security monitoring, Platform improvement, and business analytics, provided these interests do not override your fundamental rights and freedoms.
• Consent: Where processing is based on your consent (e.g., receiving marketing emails or enabling non-essential cookies), you have the right to withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

6.1 p2000m does not sell, rent, or trade your personal data to third parties. However, we may share your data with the following categories of recipients for the purposes described in this Privacy Policy:

• Payment Processors: Banks and e-wallet providers (BCA, BRI, BNI, Mandiri, CIMB Niaga, OVO, DANA, GoPay, ShopeePay, LinkAja, BSI, Bank Permata) that process your deposits and withdrawals. These processors have access only to the financial data necessary to complete transactions.
• Game Providers: Third-party studios (Pragmatic Play, Microgaming, NetEnt, Evolution Gaming, Spribe, Pocket Games Soft, etc.) that supply games on our Platform may receive technical data (such as session identifiers) necessary to deliver game content, but do not receive your identity or financial information.
• KYC and Verification Services: Specialist identity verification providers that assist p2000m in confirming your age, identity, and document authenticity as part of our regulatory compliance obligations.
• IT and Security Service Providers: Cloud hosting companies, cybersecurity firms, and technical support vendors that help us maintain, secure, and improve the Platform infrastructure.
• Professional Advisors: Legal counsel, auditors, and consultants who require access to personal data in order to provide professional services to p2000m (these parties are bound by confidentiality obligations).
• Regulatory and Law Enforcement Authorities: Gambling regulators, tax authorities, law enforcement agencies, and courts where disclosure is required by law or necessary to protect p2000m's legal rights.

6.2 All third-party service providers with access to your personal data are contractually obligated to protect it in accordance with internationally recognized data protection standards and to use it only for the specific purposes for which it was disclosed.

6.3 In the event of a business restructuring, merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity, subject to the same protections outlined in this Privacy Policy. You will be notified of any such change in ownership.

7.1 p2000m employs industry-standard technical and organizational measures to protect your personal data against unauthorized access, loss, misuse, alteration, or disclosure. These measures include:

• Encryption in Transit: All data transmitted between your device and the p2000m Platform is encrypted using TLS 1.3 / 256-bit SSL encryption.
• Encryption at Rest: Sensitive data stored on p2000m servers (including financial records and identity documents) is encrypted using AES-256 encryption.
• Access Controls: Personal data is accessible only to authorized p2000m personnel who require it to perform their job functions. Access is granted on a need-to-know basis and is protected by role-based permissions.
• Password Security: Passwords are never stored in plain text. All Member passwords are hashed using bcrypt or a comparable secure hashing algorithm.
• Network Security: Firewalls, intrusion detection systems, and regular security audits protect p2000m infrastructure from external threats.
• Secure Data Centers: Personal data is stored on servers located in secure, access-controlled data centers with physical security measures including 24/7 monitoring.
• Regular Security Audits: p2000m undergoes periodic third-party security assessments and penetration testing to identify and remediate vulnerabilities.

7.2 While p2000m takes every reasonable precaution to protect your data, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security, but we will notify you promptly in the event of any data breach that poses a risk to your rights and freedoms, in accordance with applicable data protection laws.

8.1 p2000m retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements.

8.2 Active Accounts: For active Member Accounts, we retain your personal data for the duration of your membership and for a period of 7 years following Account closure. This extended retention period is necessary to comply with financial recordkeeping requirements, AML regulations, tax obligations, and to defend against potential legal claims.

8.3 Specific Data Categories:

• Transaction Records: Deposit, withdrawal, and betting transaction records are retained for at least 7 years to comply with financial audit and tax reporting obligations.
• KYC Documents: Identity verification documents are retained for 7 years following Account closure or the end of our business relationship, as required by AML regulations.
• Marketing Preferences: If you opt out of marketing communications, we retain a suppression record indefinitely to ensure we do not contact you again.
• Technical Logs: Server logs, IP addresses, and session data are typically retained for 12 months unless longer retention is required for security investigations or legal compliance.

8.4 Once the retention period expires, personal data will be securely deleted or anonymized such that it can no longer be associated with an identifiable individual.

9.1 Under applicable data protection laws, you have the following rights with respect to your personal data held by p2000m:

• Right of Access: You have the right to request a copy of the personal data we hold about you. You may access most of your Account data directly through the Member portal. For additional information, contact our Data Protection Officer.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it. You can update most Account information yourself through the Account settings page.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where there is no compelling reason for us to continue processing it, provided we are not legally required to retain it (e.g., for financial recordkeeping, AML compliance, or ongoing investigations).
• Right to Restriction of Processing: You may request that we temporarily restrict the processing of your personal data in certain circumstances, such as while we verify the accuracy of disputed data or assess whether our legitimate interests override your rights.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit that data to another service provider where technically feasible.
• Right to Object: You have the right to object to processing of your personal data where we rely on legitimate interests as the legal basis, or to object to direct marketing at any time (you can unsubscribe from marketing emails using the link provided in each message).
• 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 processing prior to withdrawal.
• Right to Lodge a Complaint: If you believe p2000m has not handled your personal data in accordance with applicable data protection laws, you have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.

9.2 To exercise any of these rights, please submit a written request to [email protected] with the subject line "Data Protection Request". We will respond to your request within 30 days and may require identity verification to ensure we disclose information only to the rightful Account holder.

10.1 p2000m uses cookies and similar tracking technologies (such as web beacons, pixels, and local storage) to enhance your experience on the Platform, analyze usage patterns, and deliver personalized content.

10.2 Types of Cookies We Use:

• Essential Cookies: Strictly necessary for the Platform to function. These cookies enable core features such as secure login, session management, and transaction processing. Essential cookies cannot be disabled without impairing the functionality of the Platform.
• Analytical / Performance Cookies: Used to collect aggregated information about how visitors use the Platform, which pages are most popular, and where users encounter errors. This data helps us improve site performance and user experience. These cookies do not identify you individually.
• Functional Cookies: Enable enhanced functionality and personalization, such as remembering your language preference, timezone, and display settings. Functional cookies improve usability but are not essential.
• Marketing / Advertising Cookies: Used to track your activity across the Platform and deliver personalized promotional offers and content based on your betting preferences and browsing behavior. These cookies require your consent and can be disabled through your Account settings.

10.3 You can control and manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies. However, disabling essential cookies may prevent you from using certain features of the Platform. Disabling analytical or marketing cookies will not affect core functionality but may reduce personalization.

10.4 For more information on how to manage cookies in popular browsers, please consult your browser's help documentation or visit www.allaboutcookies.org (reference only; external link not provided on this page).

11.1 p2000m operates internationally and may transfer your personal data to servers and service providers located outside Indonesia. Some of these countries may not have data protection laws equivalent to those in Indonesia or the European Economic Area.

11.2 Where we transfer personal data to a country that does not provide an adequate level of data protection, we implement appropriate safeguards to protect your data, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission for data transfers to third countries;
• Binding Corporate Rules (BCRs) within corporate groups;
• Certification under recognized data protection frameworks;
• Encryption and pseudonymization techniques to minimize risk during transfer.

11.3 You may request further information about the safeguards we use for international data transfers by contacting our Data Protection Officer at [email protected].

12.1 The p2000m Platform is strictly for users aged 21 years or older. We do not knowingly collect personal data from individuals under 21 years of age.

12.2 If we become aware that we have collected personal data from a person under 21 without proper age verification, we will take immediate steps to delete that information and permanently close the associated Account.

12.3 If you are a parent or guardian and believe your child has provided personal data to p2000m, please contact us immediately at [email protected] so we can take appropriate action.

13.1 p2000m reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or business operations.

13.2 We will notify you of any material changes to this Privacy Policy by email and/or by displaying a prominent notice on the Platform at least 14 days before the changes take effect. The "Last Updated" date at the top of this page indicates when the Policy was most recently revised.

13.3 Your continued use of the Platform following the effective date of any changes constitutes your acceptance of the revised Privacy Policy. If you do not agree to the updated Privacy Policy, you must cease using the Platform and may request Account closure and data deletion (subject to our legal retention obligations).

14.1 If you have any questions, concerns, or requests regarding this Privacy Policy or how p2000m handles your personal data, please contact us:

• Email: [email protected]
• Subject Line: "Privacy Inquiry" or "Data Protection Request"
• Response Time: We will respond to privacy-related inquiries within 30 days.

14.2 For urgent security concerns (such as suspected unauthorized access to your Account), please contact our support team immediately at the email address above or through the live chat feature on the Platform.

14.3 Our Data Protection Officer is available to assist with any questions about your rights under applicable data protection laws, data retention periods, or the legal basis for processing your personal data.