gozo78 Privacy Policy

Section 1

Definitions

The following terms carry specific meanings throughout this Privacy Policy:

Section 2

Data Controller

2.1 Identity. gozo78 acts as the Data Controller for all Personal Data collected through the Platform. gozo78 is an internationally licensed online gaming operator whose platform is accessible to players in Indonesia and select other jurisdictions. All data governance decisions — including the purposes, means, and retention periods for processing your Personal Data — are determined by gozo78.

2.2 Contact. If you have any questions about how gozo78 handles your Personal Data, or if you wish to exercise any of your data subject rights described in Section 10, you may contact our Data Protection team via live chat at gozo78.asia or by emailing [email protected] (plain text — not a clickable link; please copy the address manually into your email client). Our Indonesian-speaking support team is available 24/7 and will direct your enquiry to the appropriate team within one business day.

Section 3

Data We Collect

3.1 Categories of Personal Data. gozo78 collects the following categories of Personal Data, depending on how you interact with the Platform:

3.2 Sensitive Data. gozo78 does not intentionally collect special categories of sensitive Personal Data (such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data) except where strictly required by applicable AML or responsible gaming regulations — for example, where a player's self-exclusion is linked to a documented gambling disorder. Any such data is processed only with explicit consent and is subject to enhanced security controls.

3.3 Data You Provide Voluntarily. Some data is collected only when you choose to provide it — for example, when you contact support, submit a complaint, or opt in to a promotional campaign. You are not obligated to provide this data, but withholding it may limit gozo78's ability to resolve your query or extend the relevant offer to you.

Section 4

Lawful Basis for Processing

gozo78 processes your Personal Data only where a recognised lawful basis applies. The primary bases on which gozo78 relies are:

1. Contract Performance. Processing necessary to create and maintain your Account, process deposits and withdrawals via BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay, ShopeePay, and LinkAja, settle bets, and deliver the core gaming services you have contracted for.
2. Legal Obligation. Processing required to comply with applicable AML regulations, age verification obligations, fraud prevention duties, and any lawful requests from competent regulatory or law enforcement authorities.
3. Legitimate Interests. Processing conducted for gozo78's legitimate business interests — including platform security monitoring, fraud detection, responsible gaming oversight, internal analytics, and the prevention of prohibited conduct — provided those interests are not overridden by your fundamental rights and freedoms.
4. Consent. Where gozo78 relies on your consent as the lawful basis (for example, for sending you promotional emails or SMS notifications about bonuses and seasonal offers), you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing. Withdrawal of marketing consent does not affect your Account's operational functionality.

Section 5

How We Use Your Data

gozo78 uses the Personal Data described in Section 3 for the following purposes:

• Account Creation & Management. To register your account, verify your identity and age (21+), maintain your account settings, and process your requests for account closure or modifications.
• Payment Processing. To facilitate deposits and withdrawals in IDR via your chosen Indonesian bank or e-wallet, reconcile transactions, and investigate disputed or failed payments.
• KYC & Fraud Prevention. To verify that you meet the eligibility criteria set out in our Terms & Conditions, detect and prevent fraud, money laundering, multi-accounting, and other prohibited activities, and maintain the integrity of the Platform.
• Customer Support. To respond to your enquiries, resolve complaints, process self-exclusion requests, and maintain records of interactions for quality assurance and training purposes.
• Responsible Gaming. To monitor your gaming behaviour for signs of problem gambling, enforce deposit limits and self-exclusion periods you have set, and proactively reach out if behavioural patterns suggest your play may be causing harm.
• Personalisation. To tailor the game recommendations, promotional offers, and homepage content you see on the Platform based on your gaming history and stated preferences — for example, surfacing BRI Liga 1 sportsbook markets to players who have historically wagered on Indonesian football.
• Platform Improvement. To analyse usage patterns across the Platform, identify technical issues, test new features, and optimise the performance of our games, payment flows, and support systems.
• Marketing Communications. Where you have given consent, to send you promotional emails, in-app notifications, or SMS messages about new games, seasonal bonuses (e.g., Idul Fitri, Ramadhan, and Imlek promotions), and sportsbook events relevant to Indonesian players.
• Legal Compliance. To retain records required by applicable financial regulations, respond to lawful requests from regulatory bodies, and defend gozo78's legal interests in dispute resolution proceedings.

Section 6

Data Sharing & Disclosure

6.1 Principle. gozo78 does not sell your Personal Data to third parties. gozo78 does not share your Personal Data for third-party marketing purposes. Disclosure of your data is limited to the circumstances described below.

6.2 Service Providers (Data Processors). gozo78 engages trusted third-party service providers to perform specific functions on its behalf. These providers are contractually bound to process your data only on gozo78's instructions and to maintain appropriate security standards. Categories of such providers include:

• Payment processing partners that facilitate IDR transactions via BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, OVO, DANA, GoPay, ShopeePay, and LinkAja.
• KYC and identity verification vendors that cross-reference the identity documents you submit against authoritative databases.
• Game content providers — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft — who receive anonymised session data necessary to deliver and certify their games. These providers do not receive your full identity or financial data.
• Cloud infrastructure and hosting providers that store Platform data on secured servers.
• Customer support platform providers that power gozo78's live chat and ticketing systems.
• Analytics and fraud prevention vendors that process Technical Data and Usage Data to protect the integrity of the Platform.

6.3 Legal Disclosures. gozo78 may disclose your Personal Data to competent law enforcement agencies, regulatory authorities, or courts where required to do so by applicable law, a court order, or a regulatory directive. gozo78 will use reasonable endeavours to notify you of such a disclosure in advance unless prohibited by law from doing so.

6.4 Business Transfers. In the event of a merger, acquisition, restructuring, or sale of substantially all of gozo78's assets, your Personal Data may be transferred to the acquiring entity as part of the transaction, subject to equivalent privacy protections being maintained. gozo78 will provide advance notice of any such transfer via a notice on the Platform.

6.5 Responsible Gaming Networks. Where you activate a cross-operator self-exclusion or where gozo78 is required by its licensing conditions to share self-exclusion data with a responsible gaming network, your exclusion status may be disclosed to participating operators for the sole purpose of preventing you from opening new gambling accounts during your exclusion period.

Section 7

Cookies & Tracking Technologies

7.1 What Are Cookies. Cookies are small text files placed on your device by a website you visit. gozo78 uses cookies and similar technologies (including local storage, session tokens, and pixel tags) to maintain your login session, remember your preferences, detect fraudulent activity, and measure Platform performance.

7.2 Types of Cookies Used.

• Strictly Necessary Cookies. Required for core Platform functionality — including maintaining your authenticated session, storing your cart or active bet slip state, and enabling the Platform's security features. These cookies cannot be disabled without breaking core functionality.
• Performance & Analytics Cookies. Used to measure how players navigate the Platform — which game categories are most visited, where players drop off in the registration flow, and which promotional banners drive the most engagement. Data collected by these cookies is aggregated and anonymised wherever possible.
• Functional Cookies. Used to remember your stated preferences such as language display settings, last-visited game category, and responsible gaming reminder frequency.
• Targeting & Personalisation Cookies. Used, with your consent, to deliver promotional content and bonus offers tailored to your gaming history and interests. You may opt out of these cookies at any time via your Account settings.

7.3 Managing Cookies. You may control cookie settings through your browser preferences at any time. Disabling all cookies may impair your ability to log in or use certain Platform features. Strictly Necessary Cookies cannot be disabled via browser settings as they are integral to Platform security and session management. For a full list of cookies currently in use on gozo78.asia, please contact support.

Section 8

Data Retention

8.1 Retention Periods. gozo78 retains your Personal Data only for as long as is necessary to fulfil the purpose for which it was collected, or for as long as required by applicable legal, regulatory, or contractual obligations. The following indicative retention periods apply:

• Account & Identity Data: Retained for the duration of your Account's active life, plus a minimum of 5 years following permanent Account closure, in compliance with AML record-keeping obligations.
• Transaction & Financial Data: Retained for a minimum of 5 years from the date of each transaction, as required by applicable financial regulations.
• Gaming Activity & Betting Records: Retained for a minimum of 3 years from the date of each recorded session, for responsible gaming monitoring and dispute resolution purposes.
• Customer Support Communications: Retained for 2 years from the date of last interaction, unless the communication relates to an unresolved dispute or regulatory inquiry, in which case retention is extended until final resolution.
• Marketing Consent Records: Retained for the duration of the consent period plus 3 years following withdrawal of consent, to demonstrate compliance with consent obligations.
• Technical & Log Data: Typically retained for 90 days on active systems; archived and retained for up to 12 months for security and fraud investigation purposes.

8.2 Secure Deletion. Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised using industry-standard methods so that it can no longer be attributed to you as an individual. Anonymised aggregate data may be retained indefinitely for statistical and analytical purposes.

Section 9

Data Security

9.1 Technical Measures. gozo78 applies a comprehensive set of technical security controls to protect your Personal Data against unauthorised access, disclosure, alteration, or destruction:

• 256-bit SSL (Secure Socket Layer) encryption and TLS 1.3 protocols for all data transmitted between your device and the Platform.
• AES-256 encryption at rest for all stored Personal Data and financial records held on gozo78's database servers.
• Two-factor authentication (2FA) available on all player accounts and mandatory for all gozo78 administrative system access.
• Real-time intrusion detection and prevention systems (IDS/IPS) monitoring all inbound traffic to the Platform's hosting infrastructure.
• Regular third-party penetration testing and vulnerability assessments conducted by independent cybersecurity firms.
• Strict access controls ensuring that Personal Data is accessible to gozo78 staff only on a need-to-know basis, with all access logged and auditable.

9.2 Organisational Measures. gozo78's security posture is supported by robust organisational controls, including mandatory annual privacy and data security training for all staff with access to Personal Data, formal data breach response procedures with defined escalation paths and notification timelines, and contractual data processing agreements with all third-party service providers.

9.3 Data Breach Notification. In the event of a Personal Data breach that is likely to result in a high risk to your rights and freedoms, gozo78 will notify affected players without undue delay, providing details of the nature of the breach, the categories of data affected, the likely consequences, and the measures gozo78 has taken or proposes to take to address the breach. Notification will be provided via the email address registered to your Account.

Section 10

Your Rights

As a Data Subject, you hold the following rights with respect to the Personal Data gozo78 holds about you. To exercise any of these rights, contact our support team via live chat or email — we will respond within 30 days of receiving a verified request.

• Right of Access. You have the right to request a copy of the Personal Data gozo78 holds about you, along with information about how it is being processed. gozo78 will provide this in a structured, machine-readable format where technically feasible.
• Right to Rectification. You have the right to request correction of inaccurate or incomplete Personal Data. If your registered name, address, or bank details change, please update them via your Account settings or by contacting support.
• Right to Erasure ("Right to be Forgotten"). You may request deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent (and no other lawful basis applies), or where you object to processing and gozo78 has no overriding legitimate interests. Note that this right is subject to gozo78's legal retention obligations — certain data (e.g., transaction records required by AML regulations) cannot be deleted before the mandated retention period expires.
• Right to Restriction of Processing. You may request that gozo78 restrict the processing of your Personal Data in specific circumstances — for example, while a dispute about the accuracy of your data is being resolved.
• Right to Data Portability. Where processing is based on your consent or on contractual necessity, and is carried out by automated means, you have the right to receive your Personal Data in a structured, commonly used, machine-readable format and to transmit it to another controller.
• Right to Object. You have the right to object at any time to the processing of your Personal Data on the basis of gozo78's legitimate interests, including profiling. You also have an unconditional right to object to processing for direct marketing purposes — to opt out of promotional communications, update your preferences in Account settings or contact support.
• Right to Withdraw Consent. Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

Section 11

Third-Party Services

11.1 Game Providers. The gozo78 Platform integrates games developed and hosted by third-party studios, including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft. When you launch a game, a direct connection may be established between your browser and the game provider's servers. Game providers may collect Technical Data (such as your device type and session ID) necessary to deliver the game experience. This data is governed by each provider's own privacy documentation.

11.2 Payment Processors. Deposits and withdrawals are facilitated by payment processing partners who operate the infrastructure supporting BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, OVO, DANA, GoPay, ShopeePay, and LinkAja transactions. These partners process your financial data solely to execute the transaction you have authorised and are contractually prohibited from using it for any other purpose.

11.3 No Responsibility for Third-Party Policies. gozo78 is not responsible for the privacy practices of third-party game providers, payment processors, or any external websites that may be linked to or from the Platform. We encourage you to review the privacy policies of any third-party service you interact with in connection with your gozo78 account.

Section 12

Minors

12.1 Age Restriction. The gozo78 Platform is strictly restricted to persons who are 21 years of age or older. gozo78 does not knowingly collect Personal Data from anyone under 21. Age verification is a mandatory step of the KYC process and is enforced before any real-money wagering is permitted.

12.2 Discovery of Underage Data. If gozo78 discovers or is notified that Personal Data has been collected from a person under the age of 21, that data will be deleted as promptly as is technically possible, the associated Account will be permanently closed, and any balances will be handled in accordance with our Terms & Conditions.

Section 13

International Data Transfers

13.1 Cross-Border Processing. gozo78 operates as an internationally licensed platform, and some of the service providers and game studios it works with are located outside Indonesia. Where your Personal Data is transferred to a jurisdiction that does not provide an equivalent level of data protection to that available in Indonesia, gozo78 implements appropriate safeguards — including standard contractual clauses and data processing agreements — to ensure your data remains protected to a consistent standard regardless of where it is processed.

13.2 Player Rights Unaffected. International transfers do not affect your rights as a Data Subject. All rights described in Section 10 remain exercisable regardless of the jurisdiction in which your data is stored or processed.

Section 14

Policy Amendments

14.1 Right to Update. gozo78 reserves the right to update or replace this Privacy Policy at any time to reflect changes in applicable law, our data processing practices, or the structure of the Platform. The "Last Updated" date at the top of this page will be revised each time a material change is made.

14.2 Notification of Changes. For material changes — particularly those that affect how gozo78 uses your Personal Data or the rights available to you — gozo78 will provide advance notice via a prominent notice on the Platform homepage and, where practicable, by email to your registered address, at least 7 days before the revised Policy takes effect.

14.3 Continued Use as Acceptance. Your continued use of the Platform following the effective date of any revised Privacy Policy constitutes your acknowledgement of and agreement to the updated terms. If you do not agree with the revised Policy, please cease using the Platform and request Account closure before the effective date.

Section 15

Contact

For all privacy-related enquiries, data subject rights requests, or concerns about how gozo78 processes your Personal Data, please reach our Data Protection team through the following channels:

• Live Chat: Available 24/7 at gozo78.asia — average first response under 2 minutes during WIB peak hours (18:00–01:00 WIB).
• Email: [email protected] (plain text — not a clickable link; please copy this address manually into your email client).
• Response Time: Data subject rights requests acknowledged within 5 business days; substantively responded to within 30 days of verified receipt.