ml138 Privacy Policy

1. Introduction

ml138 (the "Platform", "we", "us", or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard the personal data of users (the "User", "Player", "you", or "your") who access or use our online betting and gaming services (the "Service").

By registering an Account on ml138, depositing funds, placing bets, or otherwise using the Service, you acknowledge that you have read, understood, and consent to the data practices described in this Privacy Policy. If you do not agree to these terms, you must immediately cease all use of the Service.

This Privacy Policy should be read in conjunction with our Terms & Conditions and Responsible Gaming Policy, which together govern your use of ml138.

2. Information We Collect

ml138 collects several categories of personal information in order to provide the Service, comply with legal and regulatory requirements, and ensure platform security. The data we collect includes:

2.1 Information You Provide Directly

• Account Registration Data: Full legal name, date of birth, residential address, email address, mobile phone number, and chosen username and password.
• Identity Verification (KYC) Data: Government-issued identity documents (Indonesian National ID Card / KTP Nasional), proof of address documents (utility bills, bank statements), and selfie photographs for identity verification purposes.
• Payment Information: Bank account numbers, e-wallet account identifiers (OVO, DANA, GoPay, etc.), and transaction details related to deposits and withdrawals. We do not store full credit card numbers or CVV codes if card payments are used.
• Communication Data: Any information you provide when contacting our customer support team via live chat, email, or other communication channels, including support ticket content and chat transcripts.

2.2 Information Collected Automatically

• Device and Technical Data: IP address, device type, operating system, browser type and version, screen resolution, time zone setting, and device identifiers.
• Usage Data: Login times, pages visited, games played, bets placed, deposits made, withdrawals requested, and other activity conducted on the Platform.
• Cookies and Tracking Technologies: We use cookies, web beacons, and similar technologies to track user activity and preferences. See Section 8 for details on cookies.
• Geolocation Data: Approximate geographic location derived from your IP address to ensure compliance with geographic restrictions and prevent access from prohibited jurisdictions.

2.3 Information from Third Parties

• Payment Processors: Transaction confirmation data from banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay, ShopeePay, LinkAja).
• Identity Verification Services: Third-party KYC verification providers may supply additional identity validation data to confirm your identity and prevent fraud.
• Fraud Prevention Services: Data from fraud detection and prevention partners to identify and block suspicious activity, multi-accounting, and other prohibited conduct.

3. How We Use Your Information

ml138 uses your personal information for the following purposes:

3.1 Service Delivery

• To create, maintain, and manage your Account on the Platform.
• To process deposits, withdrawals, and other financial transactions.
• To enable you to place bets, play games, and participate in promotions.
• To calculate and credit winnings, bonuses, and loyalty rewards to your Account.
• To provide customer support and respond to your inquiries.

3.2 Legal and Regulatory Compliance

• To verify your identity and age (21+ requirement enforcement) as part of our Know Your Customer (KYC) obligations.
• To comply with anti-money laundering (AML) regulations and prevent financial crime.
• To detect, investigate, and prevent fraud, collusion, multi-accounting, bonus abuse, and other prohibited conduct.
• To respond to legal requests from law enforcement, regulators, or courts where required by law.

3.3 Security and Platform Protection

• To monitor Account activity and detect unauthorised access or suspicious behaviour.
• To implement security measures such as two-factor authentication and login verification.
• To maintain logs and audit trails for security and compliance purposes.

3.4 Platform Improvement and Analytics

• To analyse user behaviour and preferences in order to improve the Service, develop new features, and optimise user experience.
• To conduct internal research, analytics, and testing.
• To monitor platform performance and troubleshoot technical issues.

3.5 Marketing and Communications (with Consent)

• To send you promotional emails, SMS messages, or push notifications about new games, bonuses, and special offers — only if you have opted in to receive marketing communications.
• To personalise promotional content based on your gaming preferences and activity history.
• You may opt out of marketing communications at any time by clicking the "Unsubscribe" link in any email or by contacting support.

4. Data Sharing and Disclosure

ml138 does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your data with trusted third parties in the following limited circumstances:

4.1 Service Providers

We share data with third-party service providers who assist us in operating the Platform, including:

• Payment Processors: Banks, e-wallet providers, and payment gateway operators who facilitate deposits and withdrawals.
• Game Providers: Live casino studios (e.g., Evolution Gaming) and slot game developers who supply content on the Platform.
• KYC and Fraud Prevention Services: Identity verification providers and fraud detection partners who help us comply with AML/KYC regulations and prevent abuse.
• Cloud Hosting and Infrastructure Providers: Companies that host our servers and store data securely.
• Customer Support Tools: Live chat software and support ticketing systems.

All service providers are contractually required to protect your data and may only use it for the specific purposes for which it was shared.

4.2 Legal Obligations

We may disclose your information to law enforcement, regulators, courts, or government authorities if required to do so by law or in response to a valid legal request, including to:

• Comply with a subpoena, court order, or other legal process.
• Respond to requests from regulatory bodies or gaming authorities.
• Investigate or prevent fraud, security breaches, or other illegal activity.
• Protect the rights, property, or safety of ml138, our users, or the public.

4.3 Business Transfers

In the event that ml138 undergoes a merger, acquisition, sale of assets, or other corporate restructuring, your personal information may be transferred to the acquiring entity. You will be notified via email or a prominent notice on the Platform if such a transfer occurs.

5. Data Security Measures

ml138 employs industry-standard security measures to protect your personal information from unauthorised access, disclosure, alteration, or destruction. Our security measures include:

• 256-bit TLS Encryption: All data transmitted between your device and our servers is encrypted using Transport Layer Security (TLS) 1.3 or higher.
• AES-256 Document Encryption: All KYC documents (identity cards, proof of address, selfies) are encrypted with AES-256 and stored on secure, access-controlled servers.
• Two-Factor Authentication (2FA): Optional 2FA is available for all Accounts to add an additional layer of login security.
• Secure Password Storage: Passwords are hashed and salted using bcrypt or equivalent one-way cryptographic algorithms. ml138 staff cannot view or retrieve your password.
• Access Controls: Only authorised personnel with a legitimate business need can access personal data, and all access is logged and audited.
• Regular Security Audits: ml138 conducts regular internal and third-party security audits to identify and remediate vulnerabilities.

While we implement robust security measures, no system can be 100% secure. You are responsible for maintaining the confidentiality of your login credentials and should never share your password with anyone. If you suspect unauthorised access to your Account, contact support immediately at [email protected].

6. Data Retention

ml138 retains your personal information for as long as your Account is active and for a reasonable period thereafter to comply with legal, regulatory, and operational requirements.

6.1 Active Accounts

While your Account remains active, we retain all Account data, transaction history, and KYC documents to provide the Service and comply with our legal obligations.

6.2 Closed Accounts

If you close your Account, ml138 will retain certain data for the following periods:

• Transaction Records: Retained for a minimum of seven (7) years to comply with anti-money laundering regulations and tax reporting requirements.
• KYC Documents: Retained for a minimum of seven (7) years to comply with identity verification and regulatory requirements.
• Support Communications: Retained for three (3) years for quality assurance and dispute resolution purposes.
• Marketing Data: Deleted within ninety (90) days of Account closure, unless you have separately opted in to continue receiving marketing communications.

6.3 Self-Exclusion

If you self-exclude from gambling for responsible gaming reasons, your data will be retained indefinitely to prevent you from circumventing the exclusion by creating a new Account. This retention is a legal requirement under responsible gaming regulations.

7. Your Privacy Rights

Depending on your jurisdiction, you may have certain rights regarding your personal information. These rights may include:

7.1 Right of Access

You have the right to request a copy of the personal information ml138 holds about you. To request your data, contact support at [email protected] with the subject line "Data Access Request". We will respond within thirty (30) days.

7.2 Right to Rectification

If any of your personal information is inaccurate or incomplete, you may update it directly via your Account dashboard or by contacting support. Certain information (such as your name or date of birth) may require re-verification if changed.

7.3 Right to Erasure (Right to be Forgotten)

You may request that ml138 delete your personal information. However, we may be legally required to retain certain data (such as transaction records and KYC documents) for regulatory compliance purposes even after Account closure. We will delete all non-essential data upon request.

7.4 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, and machine-readable format (e.g., CSV or JSON) and to transmit that data to another service provider. Contact support to request a data export.

7.5 Right to Object or Restrict Processing

You may object to or request restriction of certain types of data processing, such as marketing communications or analytics. Note that restricting essential data processing (e.g., KYC verification, fraud detection) may prevent you from using the Service.

7.6 Right to Withdraw Consent

Where we rely on your consent to process personal data (e.g., marketing communications), you may withdraw that consent at any time by opting out via the Account dashboard or by contacting support. Withdrawal of consent does not affect the lawfulness of processing conducted prior to withdrawal.

8. Cookies and Tracking Technologies

ml138 uses cookies and similar tracking technologies to enhance user experience, analyse platform usage, and deliver personalised content.

8.1 What Are Cookies?

Cookies are small text files stored on your device by your web browser when you visit a website. Cookies allow the website to recognise your device and remember your preferences and activity.

8.2 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function. These cookies enable core features such as login, session management, and secure transactions. You cannot opt out of essential cookies.
• Performance Cookies: Collect anonymous data on how users interact with the Platform (e.g., pages visited, time spent on site) to help us improve performance and user experience.
• Functional Cookies: Remember your preferences (e.g., language, currency, display settings) to provide a personalised experience.
• Marketing Cookies: Track your activity across the Platform to deliver personalised promotions and advertisements. You may opt out of marketing cookies via your browser settings.

8.3 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can choose to block or delete cookies, but doing so may impair the functionality of the Platform. For more information on managing cookies, consult your browser's help documentation.

9. Third-Party Services and Links

The ml138 Platform may contain links to third-party websites or integrate third-party services (e.g., payment processors, game providers). ml138 is not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you interact with.

Third-party services integrated into ml138 (such as Evolution Gaming live casino tables) operate under their own privacy policies. ml138 does not control how these third parties collect, use, or share your data.

10. Changes to This Privacy Policy

ml138 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or Service features. Any changes will be effective immediately upon publication on this page.

We will notify you of material changes by email (to the address associated with your Account) or by displaying a prominent notice on the Platform. Your continued use of the Service following any amendments constitutes acceptance of the updated Privacy Policy.

We recommend that you review this Privacy Policy periodically to stay informed about how we are protecting your information.

11. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or how ml138 handles your personal information, please contact our Data Protection team:

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

This Privacy Policy was last updated on 1 January 2026. By continuing to use ml138 after this date, you acknowledge and agree to this Privacy Policy.