Last Updated: January 15, 2026 | Effective Date: January 1, 2026

Your Privacy Matters to Us

This Privacy Policy applies to all personal data collected through the neo38 platform, including our website, mobile applications, and any associated services. By using neo38, you acknowledge that you have read, understood, and agree to the practices described in this policy. If you do not agree with this Privacy Policy, please discontinue use of our services immediately.

1. Information We Collect

neo38 collects several categories of personal information to provide, maintain, and improve our services. The types of data we collect include:

1.1 Account Registration Information

When you create an account with neo38, we collect the following mandatory information:

  • Full Legal Name: Your complete name as it appears on your government-issued identification
  • Date of Birth: To verify that you meet the minimum age requirement of 21 years
  • Email Address: For account communications, security notifications, and promotional messages
  • Mobile Phone Number: For account verification, two-factor authentication, and customer support
  • Residential Address: Your current physical address in Indonesia, including city, province, and postal code
  • Username and Password: Your chosen login credentials (passwords are encrypted and never stored in plain text)

1.2 Identity Verification (KYC) Documents

To comply with anti-money laundering regulations and responsible gaming requirements, neo38 may request the following verification documents:

  • Indonesian national identity card (KTP / Kartu Tanda Penduduk)
  • Passport or driver's license (if KTP is unavailable)
  • Proof of address document (utility bill, bank statement, or government correspondence dated within the last 3 months)
  • Selfie photograph holding your identification document
  • Bank account statement or e-wallet screenshot showing your name and account details

These documents are stored securely in encrypted format and are only accessed by authorized neo38 staff for verification purposes.

1.3 Financial and Transaction Data

When you deposit or withdraw funds on neo38, we collect and process the following financial information:

  • Bank account details (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP account numbers and holder names)
  • E-wallet account information (OVO, DANA, GoPay, ShopeePay, LinkAja phone numbers and account names)
  • Transaction history (deposit amounts, withdrawal amounts, timestamps, transaction status)
  • Payment method metadata (IP address at time of transaction, device fingerprint, geolocation)

Important: neo38 does not store your banking passwords, card CVV codes, or e-wallet PINs. All payment processing is handled through secure third-party payment gateways that comply with Indonesian financial regulations.

1.4 Gaming Activity and Behavioral Data

To provide personalized experiences, detect fraud, and ensure responsible gaming practices, neo38 collects data about your activity on the platform:

  • Betting history (sports bets, casino wagers, togel selections, slot spins)
  • Game preferences (most-played games, favorite sports leagues, preferred betting markets)
  • Session duration and frequency (login times, session length, time spent per game category)
  • Win/loss records and account balance fluctuations
  • Bonus claims and wagering requirement progress
  • Customer support interactions (chat logs, email correspondence, complaint records)

1.5 Technical and Device Information

When you access neo38, we automatically collect technical data including:

  • IP address and approximate geolocation (city and province level, not precise GPS coordinates)
  • Device type, model, and operating system (e.g., Samsung Galaxy A54, Android 13)
  • Browser type and version (e.g., Chrome 120, Safari 17)
  • Screen resolution and device language settings
  • Referring URL (the website you came from before visiting neo38)
  • Clickstream data (pages visited, buttons clicked, time spent on each page)

This data helps us optimize the neo38 platform for different devices and detect unauthorized access attempts.

2. How We Use Your Data

neo38 uses the personal information we collect for the following lawful purposes:

2.1 Account Management and Service Delivery

  • Creating and maintaining your neo38 account
  • Processing deposits, withdrawals, and internal account transfers
  • Verifying your identity and age (21+ requirement)
  • Providing access to sports betting, live casino, togel, slots, and other gaming services
  • Processing your bets and wagers according to published odds
  • Crediting winnings and bonuses to your account
  • Resolving technical issues and responding to customer support inquiries

2.2 Fraud Prevention and Security

  • Detecting and preventing fraudulent transactions, money laundering, and account takeovers
  • Identifying duplicate accounts (multi-accounting violations)
  • Monitoring for collusion, chip dumping, and other forms of cheating
  • Enforcing our Terms & Conditions and resolving disputes
  • Complying with anti-money laundering (AML) and know-your-customer (KYC) regulations
  • Protecting neo38 and our members from security threats and cyberattacks

2.3 Responsible Gaming and Player Protection

  • Monitoring betting patterns to identify signs of problem gambling
  • Enforcing deposit limits, session time limits, and self-exclusion requests
  • Providing access to Responsible Gaming tools and support resources
  • Complying with age verification requirements to prevent underage gambling

2.4 Marketing and Communications

  • Sending promotional emails about bonuses, tournaments, and special offers (you can opt out at any time)
  • Delivering personalized game recommendations based on your betting history
  • Notifying you of important account updates, policy changes, and security alerts
  • Conducting customer satisfaction surveys and collecting feedback

2.5 Analytics and Platform Improvement

  • Analyzing user behavior to improve website performance and user experience
  • Testing new features and conducting A/B testing on design changes
  • Generating anonymized reports on popular games, betting trends, and user demographics
  • Optimizing mobile app performance for different Indonesian network conditions

3. Data Sharing and Disclosure

neo38 does not sell, rent, or trade your personal information to third parties for marketing purposes. We only share your data in the following limited circumstances:

3.1 Payment Processors

When you make a deposit or withdrawal, we share necessary transaction details with Indonesian banks (BCA, BRI, BNI, Mandiri) and e-wallet providers (OVO, DANA, GoPay) to process your payment. These financial institutions have their own privacy policies and are subject to Indonesian banking regulations.

3.2 Game Providers

When you play slots, live casino games, or other third-party titles, minimal session data (user ID, bet amounts, game results) is shared with game providers such as Pragmatic Play, Evolution Gaming, Microgaming, and Pocket Games Soft. This data is necessary to deliver the gaming experience and verify bet outcomes. Game providers are contractually obligated to protect your data.

3.3 Legal and Regulatory Compliance

neo38 may disclose your personal information if required by law or in response to valid legal requests from Indonesian government authorities, including:

  • Court orders, subpoenas, or search warrants
  • Requests from Indonesian financial crime enforcement agencies investigating money laundering
  • Compliance with anti-terrorism financing regulations
  • Protection of neo38's legal rights in disputes or litigation

3.4 Business Transfers

In the event that neo38 is acquired by or merged with another company, your personal data may be transferred to the acquiring entity. You will be notified via email before any such transfer occurs, and you will have the option to delete your account if you do not consent to the transfer.

3.5 Service Providers and Contractors

neo38 works with trusted third-party service providers to operate our platform, including:

  • Cloud hosting providers (for secure data storage)
  • Customer support software platforms
  • Email delivery services (for transactional and marketing emails)
  • Analytics tools (for website performance monitoring)

These service providers are contractually bound to use your data only for the purposes of providing services to neo38 and are prohibited from using it for their own purposes.

4. Data Security Measures

neo38 employs industry-standard security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction:

4.1 Encryption

  • SSL/TLS Encryption: All data transmitted between your device and neo38 servers is encrypted using 256-bit SSL (Secure Sockets Layer) technology — the same encryption standard used by major Indonesian banks like BCA and Mandiri.
  • Database Encryption: Sensitive personal data (identity documents, financial information) is encrypted at rest using AES-256 encryption.
  • Password Hashing: Your password is never stored in plain text. We use bcrypt hashing with salt to protect your login credentials.

4.2 Access Controls

  • Access to personal data is restricted to authorized neo38 employees who require it to perform their job duties (e.g., customer support, compliance team).
  • All employees with data access sign confidentiality agreements and undergo security training.
  • Multi-factor authentication (MFA) is required for all internal systems handling customer data.

4.3 Network Security

  • Firewalls and intrusion detection systems protect neo38 servers from external attacks.
  • Regular security audits and penetration testing are conducted by third-party cybersecurity firms.
  • Real-time monitoring detects and responds to suspicious activity (e.g., unusual login patterns, mass data exports).

4.4 Account Security Recommendations

While neo38 implements robust security measures, you also play a critical role in protecting your account:

  • Use a strong, unique password (minimum 12 characters with uppercase, lowercase, numbers, and symbols)
  • Never share your neo38 login credentials with anyone
  • Enable two-factor authentication (2FA) via SMS or authenticator app
  • Log out of your account when using shared or public devices
  • Be cautious of phishing emails pretending to be from neo38 (always verify the sender's email address)
  • Immediately report any unauthorized account activity to customer support

5. Data Retention Period

neo38 retains your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, and resolve disputes. Specific retention periods include:

Data Type Retention Period Reason
Account Registration Data Duration of account + 5 years Legal compliance (AML/KYC regulations)
Transaction Records 7 years from transaction date Indonesian tax and financial regulations
Betting History Duration of account + 2 years Dispute resolution and fraud investigation
Identity Documents (KYC) 5 years after account closure Anti-money laundering compliance
Customer Support Logs 3 years from last interaction Service quality improvement
Marketing Preferences Until you opt out Ongoing consent

After the retention period expires, your personal data is either securely deleted or anonymized such that it can no longer be linked to you. If you close your neo38 account, you can request immediate deletion of non-essential data, but we must retain transaction records and KYC documents to meet legal requirements.

6. Your Privacy Rights

As a neo38 user, you have the following rights regarding your personal data:

6.1 Right to Access

You have the right to request a copy of all personal data neo38 holds about you. To submit an access request, contact our customer support team via live chat or email. We will provide your data in a structured, commonly used, and machine-readable format (typically PDF or CSV) within 30 days of your request.

6.2 Right to Rectification

If any personal information we hold about you is inaccurate or incomplete, you can request corrections. You can update most account details (email, phone number, address) directly through your neo38 account settings. For changes to your legal name or date of birth, contact customer support with updated documentation.

6.3 Right to Erasure (Right to be Forgotten)

You can request deletion of your personal data in the following circumstances:

  • The data is no longer necessary for the purposes for which it was collected
  • You withdraw consent (where consent was the legal basis for processing)
  • You object to processing and there are no overriding legitimate grounds
  • Your data has been unlawfully processed

However, neo38 may refuse deletion requests if we are legally required to retain your data (e.g., for AML compliance, tax audits, or ongoing legal disputes). If deletion is not possible, we will anonymize your data instead.

6.4 Right to Restrict Processing

You can request that neo38 limit how we use your data while a dispute is being resolved. For example, if you contest the accuracy of your data, we will restrict processing until we verify its accuracy.

6.5 Right to Data Portability

You have the right to receive your personal data in a portable format and transmit it to another service provider. neo38 will provide your data in CSV or JSON format upon request.

6.6 Right to Object

You can object to processing of your personal data for direct marketing purposes at any time. To opt out of promotional emails, click the "Unsubscribe" link at the bottom of any marketing email or adjust your preferences in your account settings.

6.7 Right to Withdraw Consent

If we process your data based on consent (e.g., for marketing communications), you can withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

6.8 How to Exercise Your Rights

To exercise any of these privacy rights, contact neo38 customer support:

  • 24/7 Live Chat: Available on the neo38 website
  • Email: [email protected] (plain text — not a clickable link)
  • Subject Line: "Privacy Rights Request — [Your Username]"

We will respond to your request within 30 days. If your request is complex or we receive multiple requests from you, we may extend the response time to 60 days with notification.

7. Cookies and Tracking Technologies

neo38 uses cookies and similar tracking technologies to enhance your browsing experience, analyze website traffic, and deliver personalized content. A cookie is a small text file stored on your device that helps us recognize you on subsequent visits.

7.1 Types of Cookies We Use

  • Essential Cookies: Required for basic site functionality (e.g., keeping you logged in, remembering your language preference). These cannot be disabled.
  • Performance Cookies: Collect anonymous data about how you use neo38 (e.g., most-visited pages, error messages) to improve site performance.
  • Functional Cookies: Remember your preferences (e.g., favorite sports leagues, preferred odds format) to personalize your experience.
  • Marketing Cookies: Track your activity across websites to deliver relevant ads and measure campaign effectiveness.

7.2 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to block all cookies or accept only first-party cookies. However, disabling essential cookies may prevent you from using certain neo38 features (e.g., staying logged in). To learn how to manage cookies in your specific browser, consult your browser's help documentation.

8. Third-Party Services and Links

The neo38 platform may contain links to third-party websites (e.g., game provider sites, payment gateways, social media platforms). neo38 is not responsible for the privacy practices of these external sites. We encourage you to review the privacy policies of any third-party service before providing your personal information.

Third-party game providers (Pragmatic Play, Evolution Gaming, Microgaming, etc.) may collect data about your gameplay for their own analytics and fraud prevention purposes. Refer to each provider's privacy policy for details on their data practices.

9. Children's Privacy (21+ Requirement)

neo38 services are strictly intended for adults aged 21 years and older. We do not knowingly collect personal information from individuals under 21. If we become aware that a user is under 21, we will immediately terminate their account and delete all associated personal data.

If you are a parent or guardian and believe your child has provided personal information to neo38, please contact us immediately so we can take appropriate action.

10. Changes to This Privacy Policy

neo38 reserves the right to update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. When we make significant changes, we will notify you by:

  • Posting a prominent notice on the neo38 homepage
  • Sending an email to your registered email address
  • Displaying an in-app notification when you log in

The "Last Updated" date at the top of this page indicates when the policy was most recently revised. Your continued use of neo38 after a policy update constitutes acceptance of the new terms.

11. Contact Information for Privacy Inquiries

If you have questions, concerns, or complaints about this Privacy Policy or neo38's data handling practices, please contact us:

  • 24/7 Live Chat: Available directly on the neo38 website
  • Email: [email protected] (plain text — not a clickable link)
  • WhatsApp: +62 812-0000-3800 (plain text — not a clickable link)
  • Response Time: Live Chat <60 seconds | Email 2–6 hours (business days, WIB)

Acknowledgment: By creating an account and using neo38 services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.

256-Bit SSL Encryption

All data transmitted between your device and neo38 is protected by bank-grade encryption. Your personal information is always secure.

No Third-Party Sales

neo38 will never sell, rent, or trade your personal data to third parties for marketing purposes. Your information stays with us.

Data Minimization

We only collect the personal information necessary to provide our services and comply with legal requirements. No unnecessary data collection.

Your Rights Protected

You have full control over your data — request access, correction, deletion, or export at any time through our customer support team.

Questions About Your Privacy?

Our customer support team is available 24/7 to answer any questions you have about how neo38 handles your personal information. Whether you want to access your data, update your preferences, or request deletion, we are here to help.

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