Privacy Policy — max47

This Privacy Policy governs the collection, use, storage, and disclosure of personal data by max47 ("we", "us", "our") in connection with the online gambling platform accessible at https://max47.cam (the "Platform"). By registering an Account on the Platform or by continuing to use our services, you acknowledge that you have read, understood, and consented to the practices described in this Privacy Policy.

max47 is committed to handling your personal data responsibly and in compliance with applicable international data protection principles, including those consistent with the General Data Protection Regulation (GDPR) framework and internationally recognized privacy standards. We apply these standards to all Players regardless of their country of residence, including Players based in Indonesia.

1 Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information that identifies or can reasonably identify a living natural person, directly or indirectly — including name, date of birth, email address, IP address, financial account details, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, erasure, or destruction.
• "Data Controller" means max47 as the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of max47 under a contractual data processing agreement — such as payment providers, KYC verification services, and cloud infrastructure partners.
• "Consent" means a freely given, specific, informed, and unambiguous indication of your agreement to the processing of your Personal Data for a stated purpose.
• "Player" means any individual who has registered a verified Account on the max47 Platform.
• "Cookies" means small text files placed on your device by the Platform to store session data, preferences, and analytics information.

2 Data Controller

The Data Controller responsible for your Personal Data is max47, the operator of the Platform at https://max47.cam. max47 operates under an international gaming license and is incorporated in a jurisdiction that maintains robust data protection obligations for licensed gaming operators.

All data protection inquiries, access requests, correction requests, and deletion requests should be directed to our designated Data Protection contact:

• Email: [email protected]
• Subject Line: "Data Privacy Request – [Your Registered Email]"
• Response Time: We commit to acknowledging all data-related requests within 72 hours and resolving them within 30 calendar days.

3 Data We Collect

max47 collects Personal Data across several categories. The table below summarizes what we collect and the purpose of each category:

4 How We Collect Data

max47 collects Personal Data through the following channels:

4.1 Directly From You

• During Account registration (name, contact details, date of birth).
• During KYC verification (identity documents, selfie photographs).
• When you make a deposit or request a withdrawal (bank account or e-wallet details).
• When you contact our support team via Live Chat, email, or WhatsApp.
• When you opt in to marketing communications or loyalty programs.
• When you complete responsible gaming questionnaires or self-exclusion requests.

4.2 Automatically via the Platform

• Technical data such as IP address, device identifiers, and browser information is automatically captured each time you access the Platform.
• Usage data is captured via session tracking and analytics tools to monitor Platform performance and Player behavior.
• Cookies and similar tracking technologies record your preferences and session state (see Clause 8 for full cookie details).

4.3 From Third-Party Sources

• KYC verification providers may share identity confirmation outcomes and fraud risk scores with us.
• Payment processors (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay) may provide transaction confirmation and account validation data.
• Anti-fraud and AML screening tools may provide watchlist and sanctions screening results.

5 Purposes of Processing

max47 processes your Personal Data for the following clearly defined purposes:

1. Account Management: Creating, maintaining, and securing your Player Account, including password recovery and session management.
2. KYC & Age Verification: Verifying that you meet the minimum age requirement of 21 years and confirming your identity to comply with anti-money-laundering obligations.
3. Payment Processing: Executing your deposit and withdrawal requests via your selected Indonesian bank or e-wallet provider.
4. Service Delivery: Providing access to sports betting markets, casino games, live dealer tables, and promotional offers available on the Platform.
5. Customer Support: Resolving account queries, technical issues, payment disputes, and general support requests.
6. Security & Fraud Prevention: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, and money laundering.
7. Regulatory Compliance: Meeting our obligations under international AML and responsible gaming regulations, including maintaining records required by our licensing authority.
8. Responsible Gaming: Monitoring betting patterns, enforcing deposit limits, processing self-exclusion requests, and providing timely support to Players who may be experiencing gambling-related difficulties.
9. Marketing Communications: Sending you relevant promotional offers, bonus notifications, and platform updates where you have provided explicit consent. You may opt out at any time.
10. Platform Improvement: Analyzing usage data in aggregate and anonymized form to improve Platform performance, game selection, and user experience.

6 Legal Basis for Processing

Every instance of data processing by max47 rests on one of the following recognized legal bases:

• Contractual Necessity: Processing required to deliver the services set out in our Terms & Conditions, including account management, payment processing, and bet settlement.
• Legal Obligation: Processing required to comply with applicable laws, including KYC verification, AML screening, and regulatory record-keeping obligations imposed by our gaming license.
• Legitimate Interests: Processing carried out to pursue max47's legitimate business interests in fraud prevention, platform security, and service improvement, where these interests are not overridden by your fundamental privacy rights.
• Consent: Processing based on your freely given, specific, and informed agreement — primarily applicable to marketing communications and optional analytics tracking. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Sharing Your Data

max47 does not sell, rent, or trade your Personal Data to third parties for their own marketing purposes. We may share your data with the following categories of recipients only to the extent necessary and under strict contractual data protection obligations:

• KYC & Identity Verification Providers: Specialist third-party services that process your identity documents and selfie verification to complete KYC checks on our behalf.
• Payment Processors & Banks: Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, Bank Danamon) and e-wallet platforms (OVO, DANA, GoPay) that facilitate deposit and withdrawal transactions.
• Anti-Fraud & AML Screening Tools: Third-party services that screen transactions and account activity against sanctions lists, politically exposed persons (PEP) databases, and fraud watchlists.
• Cloud Infrastructure & Hosting Providers: Secure, enterprise-grade cloud providers that host the max47 Platform infrastructure under strict data security and confidentiality agreements.
• Customer Support Technology Partners: Live Chat and CRM software providers used to manage player communications, all operating under data processor agreements.
• Gaming Content Providers: Suppliers such as Pragmatic Play, Evolution Gaming, and Microgaming may receive anonymized session data necessary to deliver their games. They do not receive your identity or financial data.
• Regulatory & Law Enforcement Authorities: We may be legally required to disclose Personal Data to our licensing authority, financial regulators, or law enforcement agencies upon receipt of a valid legal order or in cases of suspected serious crime.

8 Cookies & Tracking

max47 uses cookies and similar tracking technologies to ensure the Platform functions correctly, to maintain your session state, and to improve the overall user experience. The following categories of cookies are used:

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling strictly necessary cookies will prevent you from logging in or using core Platform features. max47 does not use third-party advertising or retargeting cookies.

9 Data Retention

max47 retains Personal Data only for as long as is necessary to fulfill the purpose for which it was collected, or as required by our legal and regulatory obligations. The following retention periods apply:

• Active Account Data: Retained for the full duration of your Account's active status plus a minimum of 5 years following Account closure, as required by AML regulations applicable to our gaming license.
• KYC Documents: Retained for a minimum of 5 years after the end of the business relationship, in compliance with international AML and counter-terrorism financing (CTF) standards.
• Transaction Records: Deposit and withdrawal records are retained for a minimum of 5 years to satisfy financial record-keeping obligations under our licensing framework.
• Customer Support Communications: Live Chat transcripts and email correspondence are retained for 3 years from the date of the interaction to support dispute resolution and quality assurance.
• Marketing Consent Records: Records of your marketing preferences and consent status are retained for the duration of your Account plus 3 years, to demonstrate compliance with consent obligations.
• Technical & Log Data: IP addresses, device identifiers, and access logs are retained for 12 months for security monitoring purposes and then deleted or anonymized.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymized. Where anonymization is applied, the resulting data may be retained indefinitely for aggregate statistical purposes without identifying you as an individual.

10 Data Security

max47 implements a comprehensive set of technical and organizational security measures designed to protect your Personal Data against unauthorized access, accidental loss, disclosure, alteration, or destruction. Our security infrastructure includes:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the max47 Platform is encrypted in transit using industry-standard TLS 1.2 or higher protocols.
• Encryption at Rest: Sensitive data stored on our servers — including KYC documents and financial account details — is encrypted using AES-256 encryption.
• Access Controls: Access to Personal Data within max47's systems is strictly limited to authorized personnel on a need-to-know basis. All staff with data access undergo background checks and mandatory data protection training.
• Two-Factor Authentication (2FA): Players are strongly encouraged to enable 2FA on their Accounts. All internal max47 system access by staff requires mandatory 2FA.
• Penetration Testing: The Platform undergoes regular independent security audits and penetration testing to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: In the event of a data breach that is likely to result in a risk to your rights and freedoms, max47 will notify affected Players within 72 hours of becoming aware of the incident, in line with international breach notification standards.

11 Your Rights

Subject to applicable law and our legal obligations, you hold the following rights in relation to your Personal Data held by max47:

• Right of Access: You may request a copy of the Personal Data we hold about you at any time. We will provide this in a structured, commonly used format within 30 days of receiving your request.
• Right to Rectification: If any Personal Data we hold about you is inaccurate or incomplete, you have the right to request that we correct it without undue delay.
• Right to Erasure ("Right to Be Forgotten"): You may request the deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, or where you withdraw consent and no other legal basis for processing exists. Note that this right is subject to our legal retention obligations — we may be required to retain certain data even after an Account is closed.
• Right to Restriction of Processing: You may request that we restrict the processing of your Personal Data while a rectification or objection request is under review.
• Right to Data Portability: Where processing is based on your consent or contractual necessity and carried out by automated means, you may request a machine-readable copy of your Personal Data for transfer to another service provider.
• Right to Object: You have the right to object at any time to the processing of your Personal Data for direct marketing purposes. Upon receipt of such an objection, we will immediately cease sending you marketing communications.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

To exercise any of these rights, please submit a written request to [email protected] with the subject line "Data Privacy Request". We will acknowledge your request within 72 hours and respond in full within 30 calendar days. We may ask you to verify your identity before processing the request.

12 Minors

The max47 Platform is strictly intended for adults aged 21 years and over. We do not knowingly collect or process Personal Data from individuals under the age of 21. Our registration and KYC processes are designed to identify and reject applications from underage individuals.

If max47 becomes aware that Personal Data has been collected from an individual under the age of 21 — whether through a misrepresentation of age during registration or any other means — we will immediately suspend the associated Account, void all activity on that Account, and permanently delete the minor's Personal Data from our systems in accordance with our data retention policy.

Parents or legal guardians who believe that their child may have accessed or registered on the max47 Platform should contact us immediately at [email protected]. We treat all such reports as high priority and will act promptly to investigate and resolve the situation.

13 International Transfers

As an internationally operating online gaming platform serving Players primarily based in Indonesia, max47 may transfer your Personal Data to servers and service providers located in jurisdictions outside of Indonesia. Such transfers may occur when data is processed by our cloud infrastructure partners, KYC verification providers, or gaming content suppliers.

Whenever Personal Data is transferred internationally, max47 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that described in this Privacy Policy. These safeguards include:

• Contractual clauses requiring third-party recipients to handle data to an equivalent standard of protection.
• Transferring data only to service providers that maintain ISO 27001 certification or equivalent recognized information security standards.
• Conducting due diligence on all international data processors before engaging their services.

14 Policy Amendments

max47 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, we will notify you by email or by displaying a prominent notice on the Platform at least 7 days before the changes take effect.

The "Last Updated" date at the top of this page will always reflect the most recent revision. We encourage you to review this Privacy Policy periodically. Your continued use of the Platform after the effective date of any amendment constitutes your acknowledgment of the revised policy.

15 Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way max47 handles your Personal Data, please contact us through any of the following channels:

• Email: [email protected] — use subject line "Privacy Policy Inquiry" or "Data Privacy Request".
• Live Chat: Available 24/7 directly on the Platform. For data-related requests, our support agents will escalate your inquiry to our Data Protection contact within one business day.

We are committed to resolving all privacy-related complaints fairly and promptly. If you are not satisfied with our response, you have the right to escalate your complaint to the data protection supervisory authority in your jurisdiction, or to our gaming license authority's dispute resolution process.