pana93 Privacy Policy

1 Definitions

In this Privacy Policy, the following terms carry the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, date of birth, identification number, contact details, financial account information, and behavioral data generated through Platform use.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, alteration, retrieval, use, disclosure, transmission, restriction, erasure, or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this case, pana93.
• "Data Processor" means any third party that processes Personal Data on behalf of pana93 under a contractual data processing agreement.
• "Platform" means the pana93 website at pana93.cam, all associated subdomains, mobile-optimized pages, and software applications.
• "KYC" means Know Your Customer — the identity verification process required prior to processing withdrawals or upon regulatory demand.
• "Cookies" means small data files stored in your browser or device that record session information, preferences, and behavioral data related to your Platform usage.

2 Data Controller Information

pana93 operates as the Data Controller with respect to all Personal Data collected through the Platform. As Data Controller, pana93 is responsible for determining why and how your Personal Data is processed and for ensuring that processing is carried out lawfully, fairly, and transparently.

For all data protection inquiries, requests to exercise your rights, or complaints regarding our processing of your Personal Data, please contact our Data Protection Officer via the support email provided at the end of this Policy. All communications regarding personal data must include your registered account email address to enable identity verification before any data is disclosed or actioned.

3 Personal Data We Collect

3.1 Registration Data

When you create a pana93 account, we collect the following information:

• Full legal name as it appears on your government-issued identification document.
• Date of birth (used to verify the 21+ age eligibility requirement).
• Residential address, including city (e.g., Jakarta, Surabaya, Bandung, Medan, Bali) and province.
• Email address and contact telephone number.
• Username and encrypted password credentials.

3.2 Ident ity Verification (KYC) Data

To comply with our international licensing obligations and to protect the integrity of the Platform, we collect the following documentation during the KYC process:

• A copy of a valid government-issued photo identification document — such as an Indonesian National Identity Card (KTP), driver's license, or valid passport.
• Proof of residential address issued within the past three months (e.g., a utility bill or bank statement showing your name and address).
• Proof of ownership of any payment method used for deposits — for example, a screenshot or statement from your BCA, BRI, BNI, Mandiri, OVO, or DANA account confirming the account is registered in your name.
• A selfie photograph holding your identification document, where requested by our compliance team.

3.3 Transaction and Financial Data

We collect records of all financial transactions conducted through your pana93 account, including:

• Deposit amounts, timestamps, and payment method identifiers (e.g., partial bank account numbers for BCA, BRI, BNI, Mandiri; wallet IDs for OVO, DANA, GoPay, ShopeePay).
• Withdrawal requests, approved amounts, and destination payment account details.
• Bonus credits, wagering activity, and promotion redemption history.
• Account balance history and audit logs of all balance-affecting transactions.

3.4 Betting and Gaming Activity Data

We maintain records of all betting and gaming activity on your account, including sports bets placed on markets such as BRI Liga 1, EPL, La Liga, Bundesliga, Champions League, and AFF Cup fixtures; live casino game sessions; togel (Indonesia's traditional numbers lottery) draw participation; slot game sessions; and any other Platform product interactions. This data is used for account management, dispute resolution, responsible gaming monitoring, and regulatory compliance.

3.5 Technical and Device Data

When you access the Platform, our servers automatically collect certain technical information, including:

• IP address and approximate geographic location derived from IP data.
• Device type, operating system, and browser version.
• Session duration, page views, click paths, and feature interaction logs.
• Cookie identifiers and similar tracking technology outputs (see Section 9).

3.6 Communications Data

If you contact our customer support team — whether by email, live chat, or any other channel — we retain records of those communications, including the content of your messages, the date and time of contact, the resolution provided, and any follow-up actions taken. These records enable us to maintain service quality and resolve recurring issues efficiently.

4 How We Use Your Personal Data

pana93 uses the Personal Data we collect for the following purposes:

Purpose	Data Categories Used	Details
Account Creation & Management	Registration Data	To create, maintain, and administer your pana93 account and authenticate your identity on login.
Identity Verification (KYC)	KYC Data, Registration Data	To verify your identity, age (21+), and payment method ownership before processing withdrawals or as required by our licensing authority.
Payment Processing	Transaction & Financial Data	To process deposits and withdrawals via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, and ShopeePay securely and accurately.
Platform Operations	Betting Activity Data, Technical Data	To deliver the betting and gaming services you have requested, settle bets correctly, and maintain fair gameplay across all products.
Fraud & Security	All categories	To detect and prevent fraudulent activity, money laundering, bonus abuse, multi-accounting, and unauthorized access to player accounts.
Responsible Gaming	Betting Activity, Transaction Data	To monitor betting patterns for indicators of problem gambling and to administer deposit limits, time-out periods, and self-exclusion where requested or required.
Customer Support	Communications Data, Account Data	To investigate and resolve queries, disputes, and complaints submitted through our support channels.
Legal & Regulatory Compliance	All categories	To comply with applicable anti-money laundering regulations, licensing conditions, tax reporting obligations, and lawful requests from competent authorities.
Marketing Communications	Registration Data, Activity Data	To send you promotional offers, bonus notifications, and platform updates where you have provided consent or where we have a legitimate interest. You may opt out at any time.
Platform Improvement	Technical Data, Behavioral Data	To analyze aggregated, anonymized usage patterns that help us improve Platform performance, user experience, and product offerings.

5 Legal Basis for Processing

pana93 processes your Personal Data on the following legal grounds:

• Contractual Necessity: Processing required to fulfill our obligations under the Terms & Conditions you accepted upon registration — including account management, bet settlement, payment processing, and KYC verification.
• Legal Obligation: Processing required to comply with our international licensing conditions, anti-money laundering regulations, and any lawful order or request issued by a competent regulatory or law enforcement authority.
• Legitimate Interests: Processing carried out for purposes that serve pana93's legitimate business interests — including fraud prevention, Platform security, responsible gaming monitoring, and service improvement — where those interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent — primarily in respect of direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Sharing Your Personal Data

pana93 does not sell, rent, or trade your Personal Data. We share your data only in the following circumstances and only to the extent necessary for the stated purpose:

6.1 Payment Service Providers

To process deposits and withdrawals, we share necessary transaction data with our payment processing partners, including Indonesian banks (BCA, BRI, BNI, Bank Mandiri, CIMB Niaga) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja). These partners act as Data Processors under contract and are prohibited from using your data for any purpose beyond completing the relevant transaction.

6.2 KYC and Fraud Detection Partners

We engage accredited third-party identity verification and fraud detection services to assist with the KYC process and with ongoing transaction monitoring. These partners process your identification documents and transaction patterns under strict data processing agreements and are not permitted to retain or reuse your data beyond the specific verification task.

6.3 Game Studio Compliance

Game studios providing content on the Platform — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft — may receive anonymized or pseudonymized session data required for game auditing, RTP verification, and their own licensing compliance obligations. No directly identifiable personal data (name, contact details, payment information) is shared with game studios.

6.4 Regulatory and Law Enforcement Authorities

pana93 will disclose Personal Data to regulatory bodies, licensing authorities, or law enforcement agencies where required to do so by applicable law, by a valid court order, or by a lawful request from a competent authority. We will notify affected Players of such disclosures where legally permitted to do so.

6.5 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of pana93's business assets, your Personal Data may be transferred to the acquiring entity as part of that transaction, subject to equivalent privacy protections. We will notify you of any such transfer and of any changes to this Privacy Policy that result from it.

7 International Data Transfers

pana93 operates as an internationally licensed platform. As a result, your Personal Data may be stored on or accessed from servers located outside of Indonesia. Where such international transfers occur, pana93 ensures that appropriate safeguards are in place — including standard contractual clauses, binding corporate rules, or equivalent transfer mechanisms — to protect your data to a standard at least equivalent to that required under applicable data protection law.

By registering an account and using the Platform, you acknowledge and consent to the transfer of your Personal Data to countries outside Indonesia for the purposes described in this Privacy Policy. If you have questions about the specific safeguards applied to any particular transfer, please contact our Data Protection Officer.

8 Data Retention

pana93 retains Personal Data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law and our licensing obligations. The following retention principles apply:

• Active Account Data: Retained for the duration of your account's active status plus a minimum of five (5) years following permanent account closure, to satisfy anti-money laundering record-keeping requirements.
• KYC Documentation: Retained for a minimum of five (5) years from the date of last verification or account closure, whichever is later, in accordance with international licensing standards.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction for regulatory audit and dispute resolution purposes.
• Support Communications: Retained for three (3) years from the date of the last communication, unless the communication relates to an active dispute in which case it is retained until final resolution plus one (1) year.
• Marketing Consent Records: Retained for the duration of your account plus three (3) years, to demonstrate compliance with consent-based marketing obligations.
• Technical Logs: Retained for up to twelve (12) months in standard operational logs; extended retention may apply where a security investigation is ongoing.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymized so that it can no longer be linked to any identifiable individual.

9 Cookies and Tracking Technologies

9.1 What We Use

pana93 uses cookies and similar tracking technologies — including web beacons, pixel tags, and local storage objects — on the Platform for the purposes described below. By continuing to use the Platform, you consent to the use of cookies in accordance with this section.

9.2 Categories of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. They cannot be disabled without rendering the Platform inoperable.
• Functional Cookies: Store your preferences such as display language, odds format, and previously used payment methods to provide a more personalized experience across sessions.
• Analytics Cookies: Collect anonymized data about how Players interact with the Platform — including page visit frequency, session duration, and feature usage — to help us improve Platform performance and usability.
• Marketing and Retargeting Cookies: Used to deliver relevant promotional content and to measure the effectiveness of our marketing campaigns. These cookies are only set where you have provided consent.

9.3 Managing Cookies

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain categories of cookies may affect the functionality and user experience of the Platform. Detailed instructions for managing cookies in popular browsers (Chrome, Firefox, Safari, Edge) are available in each browser's help documentation.

10 Security Measures

pana93 takes the security of your Personal Data seriously and maintains a comprehensive set of technical and organizational security measures, including:

• Encryption: All data transmitted between your device and the Platform is encrypted using 256-bit SSL/TLS protocols. Sensitive data stored at rest — including payment details and KYC documents — is encrypted using AES-256 symmetric encryption.
• Access Controls: Access to Personal Data within pana93 is granted on a strict need-to-know basis. All internal access is logged, monitored, and audited regularly. Multi-factor authentication is mandatory for all staff with data access privileges.
• Penetration Testing: pana93 commissions independent security assessments and penetration tests on a periodic basis to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: In the event of a confirmed personal data breach that is likely to result in a risk to your rights and freedoms, pana93 will notify affected Players without undue delay and in accordance with applicable regulatory requirements.
• Vendor Security: All third-party Data Processors are required to demonstrate equivalent security standards as a condition of their engagement with pana93.

11 Minors and Age Restriction

pana93 is strictly an adults-only platform. We do not knowingly collect Personal Data from any individual under the age of 21. Our registration process includes a date-of-birth verification step, and our KYC procedure requires documentary proof of age for all Players prior to withdrawal processing.

If pana93 becomes aware that Personal Data has been collected from a person under the age of 21 — whether through erroneous self-reporting or any other means — we will immediately suspend the relevant account, initiate an investigation, and permanently delete all associated Personal Data where legally permissible. Parents or guardians who believe their child has registered an account on pana93 should contact our support team immediately at [email protected] (plain text — not a clickable link).

12 Exercising Your Privacy Rights

To exercise any of the data rights described in the "Your Data Rights Explained" section above — or any other rights available to you under applicable data protection law — please submit a written request to the pana93 Data Protection Officer. Your request must include:

• Your full registered name and account email address (for identity verification purposes).
• The specific right or rights you wish to exercise.
• Sufficient detail to allow us to identify the data or processing activity in question.
• A copy of your identification document where verification of identity is required before actioning the request.

pana93 will acknowledge all data rights requests within five (5) business days and will provide a substantive response or request any necessary clarification within thirty (30) calendar days of receiving the complete request. Where a request is complex or involves a large volume of data, this period may be extended by a further sixty (60) days, in which case we will notify you of the extension and the reasons for it.

We will not charge a fee for actioning data rights requests unless the request is manifestly unfounded, excessive, or repetitive, in which case a reasonable administrative fee may apply.

13 Third-Party Links and Services

The pana93 Platform may contain references to third-party services — including game studios, payment providers, and sports data providers. This Privacy Policy applies solely to Personal Data processed by pana93 in connection with the Platform. It does not extend to any third-party websites, applications, or services, even where those services are accessible through or alongside the Platform.

pana93 is not responsible for the privacy practices of any third-party service. We encourage Players to review the privacy policies of any third-party service they interact with independently of the pana93 Platform.

14 Amendments to This Privacy Policy

pana93 reserves the right to update or amend this Privacy Policy at any time. Material changes — defined as changes that significantly affect the way we collect, use, or share your Personal Data — will be communicated to you via the email address registered to your account and via a prominent notice on the Platform, with a minimum of seven (7) calendar days' advance notice before the amended Policy takes effect.

Non-material changes (such as corrections to typographical errors, clarifications that do not alter the substance of the Policy, or updates to contact information) may be made without prior notice and will take effect immediately upon publication. The "Last Updated" date at the top of this Policy will reflect the most recent revision date in all cases.

Your continued use of the Platform following the effective date of any amended Privacy Policy constitutes your acceptance of the changes. If you do not agree with any amendment, you must cease using the Platform and contact support to request account closure and return of your verified balance.

15 Contact and Complaints

For all privacy-related inquiries, requests to exercise your data rights, or formal complaints regarding pana93's handling of your Personal Data, please contact our Data Protection Officer. Our support team is available 24 hours a day, 7 days a week, including Indonesian public holidays such as Idul Fitri, Indonesian Independence Day (17 August), Nyepi, and Christmas.

Data Protection Contact: [email protected] (plain text — not a clickable link)

Please include "Privacy Request" or "Data Protection" in your message subject line, along with your registered account email address, to ensure your inquiry is directed to the appropriate team without delay.

If you are not satisfied with pana93's response to a privacy complaint, you have the right to escalate your complaint to the relevant data protection authority or to the dispute resolution body designated by our licensing authority. Details of the applicable escalation path will be provided in our response to your initial complaint.