Privacy Policy

1 Introduction & Scope

This Privacy Policy ("Policy") is issued by moon33 ("the Company", "we", "us", "our"), the operator of the online betting and gaming platform accessible at https://moon33.cam. It applies to all personal data processed in connection with your use of the moon33 platform, whether you access it via a web browser, mobile device, or any other means.

moon33 primarily serves English-preference players based in Indonesia. By registering an account or otherwise using our services, you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal data as described herein.

This Policy should be read in conjunction with the moon33 Terms & Conditions, which govern the overall legal relationship between you and moon33. In the event of any conflict between this Policy and the Terms & Conditions on a privacy-related matter, this Policy shall prevail.

2 Personal Data We Collect

moon33 collects personal data across several categories depending on the nature of your interaction with the platform. The following table outlines the main data categories and the context in which they are collected:

We do not collect any special-category data (such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data) unless specifically required by applicable law or where you have provided explicit consent.

3 How We Use Your Personal Data

moon33 uses the personal data we collect for the following defined purposes only:

3.1 Account Management and Service Delivery

We use your identity and contact data to create and maintain your account, authenticate your login sessions, process your deposit and withdrawal transactions, and deliver the gaming products and betting markets available on the platform.

3.2 Identity Verification and Fraud Prevention

We use identity, financial, and technical data to fulfill our Know Your Customer (KYC) obligations, verify your age and eligibility (you must be at least 21 years of age and a resident of Indonesia), and detect, investigate, and prevent fraudulent activity, money laundering, and other prohibited conduct as defined in the Terms & Conditions.

3.3 Responsible Gaming Compliance

We use gaming activity data and responsible gaming data to monitor for indicators of problem gambling behavior, enforce player-requested limits and self-exclusion measures, and contact players proactively where our monitoring systems flag potential concerns. This is a legitimate and important use of your data that serves your direct interests.

3.4 Customer Support

We use communications data to respond to your support queries, resolve account disputes, and improve our service quality. Our support agents are available in both English and Indonesian 24 hours a day, 7 days a week.

3.5 Legal and Regulatory Compliance

We process personal data to the extent necessary to comply with applicable laws, regulations, court orders, and requests from competent authorities in the jurisdictions in which moon33 operates.

3.6 Platform Improvement and Analytics

We use aggregated and anonymized technical and gaming activity data to analyze platform performance, identify technical issues, improve the user experience, and inform product development decisions. This analysis does not involve data that identifies individual players.

3.7 Direct Marketing

Where you have given explicit consent, we may send you promotional communications about bonuses, new games, and seasonal offers relevant to Indonesian players — including campaigns tied to Ramadhan, Idul Fitri / Lebaran, BRI Liga 1 season milestones, and major international sporting events. You may withdraw your consent to marketing communications at any time by contacting support.

4 Legal Basis for Processing

moon33 processes personal data only where a valid legal basis exists. The legal bases on which we rely are as follows:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions — including account setup, transaction processing, and game delivery.
• Legal Obligation: Processing required to comply with applicable laws, including AML regulations, KYC requirements, and responses to lawful authority requests.
• Legitimate Interests: Processing carried out for fraud prevention, platform security, responsible gaming monitoring, service improvement, and account integrity. We carefully balance these legitimate interests against your rights and preferences.
• Consent: Processing for optional activities such as direct marketing, where you have provided explicit, freely-given, and revocable consent.

5 Sharing Your Personal Data

moon33 does not sell, rent, or trade your personal data to any third party for marketing or advertising purposes. We share personal data only in the limited circumstances described below, always with appropriate contractual safeguards in place.

5.1 Service Providers

We share personal data with trusted service providers who support the operation of the platform under strict data processing agreements. These providers include:

• Payment Processors: Banking and e-wallet partners that process deposits and withdrawals in IDR, including BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon, BSI, OVO, DANA, GoPay, ShopeePay, and LinkAja.
• Game Providers: Licensed third-party game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft, whose games are embedded on the platform.
• Technology and Hosting Providers: Infrastructure providers, cloud hosting services, and security vendors who process data on our behalf.

5.2 Legal and Regulatory Authorities

We may disclose personal data to competent courts, law enforcement agencies, regulators, or other governmental authorities where such disclosure is required by law, where necessary to establish, exercise, or defend legal claims, or where we believe in good faith that disclosure is necessary to protect the safety of players or the public.

5.3 Business Transactions

In the event of a merger, acquisition, reorganization, or transfer of assets, personal data may be transferred to the acquiring entity as part of the transaction. Where such a transfer occurs, the receiving entity will be bound by data protection obligations at least as protective as those described in this Policy.

5.4 Aggregated and Anonymized Data

We may share aggregated, de-identified, or anonymized data that cannot be used to identify any individual player with third parties for analytical, research, or statistical purposes. Such data does not constitute personal data under applicable laws.

6 Cookies & Tracking Technologies

moon33 uses cookies and similar tracking technologies to ensure the proper functioning of the platform, to remember your login state, and to gather anonymized analytics that help us improve the service. This allows us to maintain a secure and reliable user experience.

6.1 Types of Cookies Used

6.2 Managing Cookies

You can control and/or delete cookies at any time through your browser settings. Please note that disabling strictly necessary cookies may prevent you from accessing or using certain features of the platform. For more information, we encourage you to consult the "Help" section of the web browser you are using.

moon33 does not use third-party advertising cookies, and we do not use cookies to deliver targeted marketing content to you on external websites or platforms.

7 Data Retention

moon33 retains personal data only for as long as necessary to fulfill the purposes described in this Policy, or for a longer period where required by applicable law or regulation. The retention period for different data categories is determined by reference to the following criteria:

• Purpose fulfilment: Data is retained for the duration of your account relationship with moon33 plus a reasonable period thereafter to handle any outstanding transaction inquiries, disputes, or support requests.
• Legal obligations: Where required by AML, KYC, anti-fraud, or tax regulations, certain records — including identity verification documents and transaction history — are retained for the legally mandated period, typically 5 to 7 years after the closure of your account.
• Dispute resolution: If a legal claim, complaint, or investigation is pending, relevant data is retained until the matter is fully resolved.

Once the applicable retention period has elapsed, personal data is securely deleted, destroyed, or anonymized so that it can no longer be attributed to you.

8 Data Security

Protecting your personal data is one of moon33's highest priorities. We have implemented a layered security architecture comprising technical, organizational, and administrative measures designed to protect personal data against unauthorized access, alteration, disclosure, or destruction.

Our security measures include, but are not limited to:

• Encryption in transit: All data transmissions between your device and the platform are protected by 256-bit SSL/TLS encryption.
• Encryption at rest: Sensitive personal data is stored in encrypted databases using industry-standard key management practices.
• Access control: Employee access to personal data is restricted on a need-to-know basis and monitored through strict internal access policies and audit trails.
• System monitoring: Continuous threat monitoring and regular penetration testing are carried out to identify and address potential security vulnerabilities.
• Provably Fair systems: Games offered on the platform utilize provably fair RNG systems, ensuring game outcomes are verifiably random and tamper-resistant.
• Account security features: Two-factor authentication (2FA) is available and encouraged for all player accounts, providing an additional layer of protection against unauthorized access.
• Incident response: A dedicated security response framework is in place to notify affected players of any data breach incident in accordance with applicable law.

While we take all reasonable steps to protect your personal data, no method of transmission over the internet or method of electronic storage is completely secure. Accordingly, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your login credentials and for notifying moon33 immediately of any suspected unauthorized use of your account.

9 Your Rights as a Data Subject

Moon33 recognizes that you have certain rights in relation to your personal data. Subject to applicable law and any legitimate restrictions, you may exercise the following rights:

• Right of Access: You may request a copy of the personal data we hold about you, together with a description of how we process it.
• Right to Rectification: You may request that we correct any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you have withdrawn consent and there is no other legal basis for continued processing.
• Right to Restriction of Processing: You may request that we suspend the processing of your personal data in specific circumstances, for example while a dispute regarding accuracy is being resolved.
• Right to Data Portability: Where processing is based on consent or contract and is carried out by automated means, you may request a copy of your data in a structured, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests, including processing for direct marketing purposes or responsible gaming monitoring, and we shall cease such processing unless we demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where you have provided consent for a specific processing activity (such as receiving marketing communications), you may withdraw that consent at any time.

To exercise any of these rights, please contact our support team at [email protected]. We will respond to all verified data subject requests within 30 days of receipt, in accordance with applicable law. We may require you to verify your identity and account ownership before processing a request.

10 Children's Privacy

The moon33 platform is strictly intended for individuals who are at least 21 years of age. We do not knowingly collect, solicit, or process personal data from minors or from any person under the age of 21. No one under the age of 21 may provide any personal information to moon33, and we do not knowingly permit persons under the age of 21 to register an account or use the platform.

If you believe that a person under the age of 21 may have provided personal data to moon33, please contact us immediately at [email protected] and we will take prompt steps to delete such data and close any associated account.

Certain gambling-related games — including togel (Indonesia's traditional numbers lottery) — are available on the platform. These are strictly restricted to eligible adults aged 21 and above, and moon33 does not market these products to minors.

11 International Data Transfers

moon33 is an internationally operated platform. As such, personal data collected from players in Indonesia may be transferred to, stored at, and processed in jurisdictions outside the territory of Indonesia. These jurisdictions may not have data protection laws equivalent to those applicable in your country of residence.

Where personal data is transferred internationally, moon33 ensures that appropriate safeguards are in place to protect your data. These safeguards may include:

• Standard contractual clauses adopted or approved by competent supervisory authorities.
• Verification that the receiving jurisdiction maintains a level of data protection deemed adequate.
• Internal data transfer agreements that impose data protection obligations no less stringent than those described in this Policy.

By using the moon33 platform and providing your personal data, you consent to the international transfer, processing, and storage of that data as described in this Section 11.

12 Changes to This Privacy Policy

moon33 may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or operational configurations. Where changes are material, we will notify you by email to the address registered on your account and/or by displaying a prominent notice on the platform for a reasonable period before the revised policy takes effect.

The "Last updated" date at the top of this page indicates the date of the most recent policy revision. Your continued use of the platform following the effective date of any policy change constitutes your acceptance of the revised Policy. If you do not agree with the changes, you must stop using the platform and may request account closure by contacting support. Any balance held in your account will be returned to you, subject to standard KYC and withdrawal conditions.

13 Contact & Complaints

If you have any questions about this Privacy Policy, the personal data moon33 holds about you, or the way your data is handled, please contact our dedicated privacy team using the following details:

If you are not satisfied with how we have handled your data concern, you may escalate your complaint to our compliance team by emailing the same address with the subject line "Data Complaint". You also have the right to lodge a complaint with a competent data protection supervisory authority in your jurisdiction, where such rights exist under applicable law.

Please provide your account username and a detailed description of your concern in all data-related correspondence to assist us in resolving your request as quickly as possible.