Privacy Policy

1. Introduction

1.1 usa93 is committed to handling the personal data of our Players with integrity, transparency, and care. We recognize that our Indonesian players entrust us with sensitive personal and financial information, and we take that responsibility seriously.

1.2 This Policy applies to all personal data we collect when you visit our website, register an account, make a deposit or withdrawal, participate in promotions, contact our support team, or otherwise interact with our platform.

1.3 This Policy does not apply to third-party websites that may be linked from our platform. We encourage you to review the privacy policies of any third-party services you access independently.

2. Definitions

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

• "Personal Data" — Any information that identifies or can reasonably be used to identify a living individual, including name, email address, phone number, national identity number, and financial account details.
• "Processing" — Any operation performed on personal data, including collection, storage, use, disclosure, modification, or deletion.
• "Data Controller" — usa93, as the entity that determines the purposes and means of processing your personal data.
• "Data Processor" — Any third-party service provider that processes personal data on behalf of usa93 under a written data processing agreement.
• "KYC Data" — Documents and information collected for identity verification purposes, including identity cards, proof of address, and selfie verification photographs.
• "Cookies" — Small text files stored on your device by our website to support functionality, session management, and platform analytics.

3. Data We Collect

3.1 usa93 collects the following categories of personal data from Players:

Category	Examples	Purpose
Identity Data	Full legal name, date of birth, national ID (KTP) number, photograph	Account registration, KYC verification, age compliance
Contact Data	Email address, Indonesian mobile phone number, residential address	Account communication, support, verification notices
Financial Data	Bank account name and number (BCA, BRI, BNI, Mandiri, etc.), e-wallet IDs (OVO, DANA, GoPay), transaction history	Deposits, withdrawals, fraud prevention
Technical Data	IP address, browser type, device type, operating system, session duration, pages visited	Platform security, fraud detection, performance optimization
Gaming Activity Data	Game history, bet records, wagering totals, bonus usage, win/loss records	Service delivery, responsible gaming monitoring, dispute resolution
Communications Data	Live chat transcripts, email correspondence, support ticket content	Customer service, quality assurance, dispute resolution

3.2 We do not collect special category data (such as racial origin, political opinions, health data, or biometric data beyond what is strictly required for KYC purposes).

4. How We Collect Data

4.1 Direct Collection: The majority of your personal data is collected directly from you at the point of registration, during KYC submission, when you make transactions, or when you contact our support team.

4.2 Automated Collection: When you access our platform, certain technical data is collected automatically through server logs and cookies. This includes your IP address, browser configuration, and session behavior. See Section 10 for full cookie details.

4.3 Third-Party Sources: In limited circumstances, usa93 may receive data about you from third-party identity verification services, fraud prevention databases, or payment processors in order to comply with our anti-fraud and KYC obligations. Such third-party data processing is governed by separate data processing agreements.

5. Purpose of Processing

5.1 usa93 processes your personal data for the following purposes:

• Account Management: To create, maintain, and administer your player account, including identity verification and account security;
• Service Delivery: To process deposits and withdrawals via Indonesian bank accounts (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja), and to provide access to all gaming services;
• Legal Compliance: To fulfill our obligations under applicable law, including anti-money laundering (AML) checks, KYC requirements, and responsible gaming regulations;
• Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, account abuse, and other prohibited conduct;
• Customer Support: To respond to inquiries, resolve disputes, and provide assistance to Players;
• Responsible Gaming: To monitor gaming activity, enforce self-exclusion requests, and identify Players who may require responsible gaming intervention;
• Platform Improvement: To analyze user behavior and platform performance to improve our services, fix technical issues, and enhance user experience;
• Direct Marketing: Where you have given consent, to send you promotional offers, bonus notifications, and platform updates. You may withdraw marketing consent at any time.

6. Legal Basis for Processing

6.1 usa93 processes your personal data on one or more of the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between usa93 and the Player — specifically, to operate your account, process transactions, and deliver gaming services;
• Legal Obligation: Processing is required to comply with applicable legal and regulatory requirements, including KYC, AML, and responsible gaming obligations;
• Legitimate Interests: Processing is necessary for usa93's legitimate interests, including fraud prevention, platform security, and service improvement, provided these interests do not override your fundamental rights and freedoms;
• Consent: Where you have provided explicit consent, such as for direct marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

7. Data Sharing & Disclosure

7.1 usa93 does not sell your personal data. We may share your data only in the following limited circumstances:

• Service Providers: Third-party suppliers engaged to support our operations — including payment processors, identity verification services, cloud hosting providers, and customer support platforms — may access personal data strictly as needed to perform their services. All such providers are bound by data processing agreements obligating them to maintain confidentiality and process data only on our instructions;
• Game Studios: When you access games provided by third-party studios (e.g., Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Pocket Games Soft), limited technical data (such as your player session token) may be shared with that studio to deliver the game experience. No financial data is shared with game studios;
• Legal Authorities: We may disclose personal data to law enforcement, regulatory authorities, or courts if required to do so by applicable law, a valid court order, or where we have a good-faith belief that disclosure is necessary to investigate fraud, money laundering, or other serious criminal activity;
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of usa93's assets, personal data may be transferred to the successor entity, subject to equivalent data protection obligations.

7.2 Outside of these circumstances, we will not disclose your personal data to any third party without your explicit prior consent.

8. Data Retention

8.1 usa93 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulation.

8.2 The following general retention periods apply:

• Account and identity data: Retained for the duration of the active account relationship, plus a minimum of 5 years following account closure, in accordance with standard AML record-keeping obligations;
• Transaction and financial records: Retained for a minimum of 5 years from the date of the transaction;
• KYC documents: Retained for a minimum of 5 years from the date of verification or account closure, whichever is later;
• Customer support communications: Retained for 3 years from the date of the interaction;
• Technical and session logs: Retained for 12 months from the date of collection, after which they are anonymized or deleted;
• Marketing consent records: Retained until consent is withdrawn, plus 12 months thereafter as evidence of the consent transaction.

8.3 When personal data is no longer required, usa93 will securely delete or anonymize it in accordance with our internal data destruction procedures.

9. Security Measures

9.1 usa93 implements a layered set of technical and organizational security measures to protect your personal data against unauthorized access, loss, alteration, or disclosure. These measures include:

• Encryption in transit: All data exchanged between your browser and our servers is encrypted using TLS 1.2 or higher, enforced via an SSL certificate with HSTS headers;
• Encryption at rest: Sensitive data fields, including financial account numbers and identity document data, are encrypted at rest using AES-256;
• Access controls: Internal access to personal data is restricted on a strict need-to-know basis, governed by role-based access control (RBAC) policies. All internal access is logged and auditable;
• Two-factor authentication: Administrative access to data systems requires multi-factor authentication;
• Penetration testing: Our platform undergoes periodic security assessments and vulnerability testing by qualified security professionals;
• Incident response: usa93 maintains a documented data breach response plan. In the event of a breach that poses a risk to affected Players, we will notify impacted individuals without undue delay.

9.2 While usa93 applies all reasonable technical safeguards, no internet-based system is entirely immune from risk. Players are responsible for maintaining the security of their own login credentials and for notifying usa93 immediately if they suspect unauthorized account access.

10. Cookies & Tracking Technologies

10.1 usa93 uses cookies and similar technologies to operate and improve our platform. The following categories of cookies are in use:

Cookie Type	Purpose	Retention
Strictly Necessary	Session management, login state, security tokens. Cannot be disabled without impairing platform functionality.	Session / up to 24 hours
Functional	Remembering your language preference, display settings, and recently viewed pages to improve your experience.	Up to 30 days
Analytics	Anonymized usage statistics to help us understand how Players navigate the platform and identify areas for improvement.	Up to 12 months
Fraud Prevention	Device fingerprinting and behavioral signals used to detect and prevent fraudulent login attempts and multi-account abuse.	Up to 6 months

10.2 usa93 does not use third-party advertising cookies or behavioral retargeting pixels. Our analytics cookies collect anonymized, aggregated data only.

10.3 You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to log in and use core platform features. Disabling functional or analytics cookies will not prevent you from accessing the platform.

11. Your Rights

11.1 As a Player on usa93, you have the following rights with respect to your personal data:

11.2 To exercise any of these rights, please contact our support team at [email protected] with the subject line "Data Rights Request". We will acknowledge your request within 5 business days and provide a substantive response within 30 calendar days. In complex cases, this period may be extended by a further 30 days, in which case we will notify you of the extension.

11.3 Where a request is manifestly unfounded or excessive, usa93 reserves the right to charge a reasonable administrative fee or decline to act on the request, providing written reasons for that decision.

12. Minors

12.1 usa93 strictly prohibits the use of its platform by any person under the age of 21. We do not knowingly collect personal data from minors. Our registration process includes mandatory age declarations, and our KYC process requires identity document verification that confirms date of birth.

12.2 If usa93 becomes aware that personal data has been collected from an individual under 21 years of age, we will take immediate steps to close the account, delete all associated personal data, and — where applicable — reverse any transactions associated with that account.

12.3 Parents or guardians who believe a minor has registered on usa93 should contact us immediately at [email protected]. We will investigate and act on all such reports as a matter of priority.

13. International Data Transfers

13.1 usa93 primarily serves Indonesian players and aims to process personal data within secure data center environments. In the course of operating our platform, some personal data may be processed by service providers whose infrastructure is located outside Indonesia.

13.2 Where personal data is transferred to third-party processors outside the country of collection, usa93 ensures that appropriate safeguards are in place, including data processing agreements that incorporate internationally recognized data transfer protections and confidentiality obligations consistent with applicable data protection standards.

13.3 By using usa93, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside Indonesia for the operational purposes described in this Policy.

14. Changes to This Policy

14.1 usa93 may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform features. Where changes are material, we will notify registered Players via the email address associated with their account and publish a prominent notice on the platform for a period of not less than 14 days before the revised Policy takes effect.

14.2 The date of the most recent revision is displayed at the top of this page. Your continued use of the platform after the effective date of any revision constitutes your acceptance of the updated Policy. We recommend reviewing this page periodically to stay informed of how usa93 protects your data.

14.3 If you do not agree with any revised version of this Policy, you must cease using the platform and may request account closure by contacting our support team.

15. Contact

If you have any questions, concerns, or requests relating to this Privacy Policy or the way usa93 handles your personal data, please contact our dedicated data support team. We aim to resolve all privacy-related inquiries promptly and transparently.