Privacy Policy

1. Introduction

hoki22 ("we," "us," "our") operates an online betting platform at https://hoki22.cam serving players primarily in Indonesia. We recognize that your personal information is valuable and sensitive, and we are committed to protecting your privacy in accordance with international data protection standards including principles aligned with the General Data Protection Regulation (GDPR), although we acknowledge that Indonesia has its own data protection framework under Law No. 27 of 2022 on Personal Data Protection (UU PDP).

This Privacy Policy applies to all users of hoki22 services, including visitors to our website, registered account holders, and anyone who interacts with our platform or customer support channels. This policy works in conjunction with our Terms & Conditions to form the complete legal agreement between you and hoki22. If any conflict arises between this Privacy Policy and the Terms & Conditions, the Terms & Conditions shall prevail except where specific privacy rights are granted by applicable law.

Data Controller: hoki22 acts as the data controller for personal information collected through our platform. We determine the purposes and means of processing your personal data. For questions about data processing or to exercise your privacy rights, please contact us using the details provided in Section 12 of this policy.

2. Information We Collect

To provide you with a secure, personalized betting experience and to comply with legal obligations including anti-money laundering (AML) and Know Your Customer (KYC) regulations, hoki22 collects several categories of personal information:

2.1 Information You Provide Directly

• Account Registration Data: When you create an account, we collect your full legal name (as it appears on your Indonesian National Identity Card / KTP or passport), date of birth, gender, email address, phone number, residential address (street, city, province, postal code), and preferred username/password.
• Identity Verification Documents: To verify your identity and comply with KYC requirements, we collect copies of government-issued identification documents (KTP, passport, driver's license), selfie photographs holding your ID, proof of address documents (utility bills, bank statements), and banking information (account holder name, bank name, account number for deposits and withdrawals).
• Financial Transaction Data: We record all deposit and withdrawal transactions including amounts, dates, times, payment methods used (BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay), transaction reference numbers, and transaction status.
• Communication Records: When you contact customer support via live chat, email, or phone, we retain transcripts and recordings of those interactions for quality assurance, training, and dispute resolution purposes.
• Voluntary Information: Any additional information you choose to provide in your profile, preferences, feedback forms, or surveys.

2.2 Information Collected Automatically

• Betting and Gaming Activity: We log all bets placed including bet type, stake amount, odds, selections, outcomes, winnings/losses, game sessions, time spent on different games, and overall account activity history.
• Device and Technical Data: When you access hoki22, we automatically collect your IP address, device type (desktop, mobile, tablet), operating system, browser type and version, screen resolution, device identifiers (such as IMEI or advertising IDs where permitted), and language preferences.
• Website Usage Data: We track pages visited, clickstream data (the path you take through our site), time spent on each page, referring/exit pages, date and time stamps, and interaction with specific features or content.
• Location Information: We derive approximate geographic location from your IP address to ensure compliance with territorial restrictions and to provide localized services (such as displaying odds in WIB timezone and processing payments via Indonesian banks).
• Cookies and Similar Technologies: We use cookies, web beacons, pixels, and similar tracking technologies as described in Section 8 of this policy.

2.3 Information from Third Parties

• Payment Processors: Our banking and e-wallet partners (including BCA, BRI, BNI, Mandiri, OVO, DANA, GoPay payment gateways) may share transaction confirmation data, payment status updates, and fraud prevention signals.
• Identity Verification Services: We may use third-party KYC verification providers to validate your identity documents and cross-reference your information against fraud databases, sanctions lists, and politically exposed persons (PEP) watchlists.
• Game Providers: When you play games from third-party studios (Pragmatic Play, Evolution Gaming, Microgaming, etc.), those providers may share game outcome data, session information, and fair-play monitoring signals with us.
• Marketing Partners: If you arrive at hoki22 through an affiliate or marketing partner, we may receive limited referral data such as the source website and campaign identifier, but never your pre-existing personal information unless you separately provided it to that partner.

3. How We Use Your Data

hoki22 processes your personal information for the following purposes, each grounded in a lawful basis under applicable data protection law:

3.1 Service Delivery and Account Management (Contractual Necessity)

We use your data to create and maintain your betting account, process your deposits and withdrawals, settle bets and distribute winnings, provide customer support, communicate account-related notifications (such as successful deposits, withdrawal confirmations, bonus credits), and generally fulfill our obligations under the Terms & Conditions you agreed to when registering.

3.2 Legal and Regulatory Compliance (Legal Obligation)

We process your identity and financial data to comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations, verify that you meet minimum age requirements (21+ in Indonesia), prevent fraud and detect suspicious activity, respond to lawful requests from government authorities or regulators, maintain records as required by our licensing jurisdiction, and enforce our Terms & Conditions and other policies.

3.3 Security and Fraud Prevention (Legitimate Interest)

We analyze behavioral data, device information, and betting patterns to detect and prevent fraudulent activity, collusion, bonus abuse, account takeovers, payment fraud, and other security threats. This protects both hoki22 and our legitimate player community. Our legitimate interest in maintaining platform integrity and protecting our business outweighs any minimal privacy impact, as this processing is essential to fair gaming.

3.4 Platform Improvement and Analytics (Legitimate Interest)

We use aggregated and anonymized data to understand how players use our platform, which games are most popular, where users experience friction in the deposit or betting process, and how we can improve overall user experience. This analytics work helps us optimize site performance, develop new features, and make data-driven product decisions. Individual players are not identifiable in these analyses.

3.5 Marketing and Personalization (Consent / Legitimate Interest)

With your consent (where required by law), we may send you promotional emails, SMS messages, or push notifications about new games, bonus offers, special promotions, and hoki22 news. You can opt out of marketing communications at any time using the unsubscribe link in emails or by adjusting your account preferences. We may also personalize your experience on hoki22 by showing you relevant game recommendations or tailored bonus offers based on your betting history, which constitutes our legitimate interest in providing a better user experience.

3.6 Responsible Gaming Monitoring (Legal Obligation / Legitimate Interest)

We monitor account activity for signs of problem gambling behavior (such as rapidly escalating deposits, long continuous play sessions, frequent use of deposit limit increases, or expressions of distress in customer support conversations) so that we can proactively intervene with Responsible Gaming resources, suggest self-exclusion tools, or implement mandatory cooling-off periods. This processing is both a legal obligation under responsible gaming regulations and a legitimate interest in player welfare.

4. Data Sharing & Disclosure

hoki22 does not sell your personal information to third parties. However, we share your data with carefully selected partners and service providers under strict confidentiality agreements in the following circumstances:

4.1 Service Providers and Business Partners

• Payment Processors: We share necessary financial information (your name, bank account number, transaction amount) with Indonesian banks (BCA, BRI, BNI, Mandiri, etc.) and e-wallet providers (OVO, DANA, GoPay) to process deposits and withdrawals.
• Identity Verification Providers: KYC/AML compliance partners receive your identity documents and personal details to verify your identity and screen for sanctions/PEP status.
• Game Content Providers: When you play games from Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, or other third-party studios, those providers receive your player ID and session data to deliver the game experience, but they do not receive your full personal profile or financial information.
• Cloud Infrastructure Providers: Our website and databases are hosted on secure cloud servers (AWS, Google Cloud, or similar enterprise providers), which store your data but are contractually prohibited from accessing or using it except as necessary to provide hosting services to hoki22.
• Customer Support Software: We use third-party live chat and help desk platforms to manage customer support interactions; these providers have access to support transcripts but are bound by strict data processing agreements.
• Analytics and Marketing Tools: We use industry-standard analytics platforms (Google Analytics or similar, with IP anonymization enabled) and may share anonymized or pseudonymized data with marketing partners to measure campaign effectiveness.

All third-party service providers are carefully vetted and contractually obligated to protect your data, use it only for the specific purposes we authorize, and comply with applicable data protection laws. We conduct regular audits of our key partners to ensure ongoing compliance.

4.2 Legal and Regulatory Disclosure

We may disclose your personal information without your consent when required or permitted by law:

• To comply with a court order, subpoena, warrant, or other legal process;
• To respond to lawful requests from government authorities, regulators, or law enforcement agencies;
• To investigate, prevent, or take action regarding suspected fraud, illegal activities, threats to physical safety, or violations of our Terms & Conditions;
• To protect the rights, property, or safety of hoki22, our users, or the public;
• In connection with a corporate transaction such as a merger, acquisition, bankruptcy, or sale of assets, in which case your data would be transferred to the acquiring entity (you would be notified of such a transfer).

4.3 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you with business partners, researchers, or the public for purposes such as industry analysis, benchmarking, or marketing. For example, we might publish statistics like "hoki22 processed 1 million bets on BRI Liga 1 matches in January 2026" without revealing any individual player information.

5. Data Security

hoki22 employs industry-leading technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

Your Role in Security: While we implement robust security measures, you also play a critical role in protecting your account. Please use a strong, unique password, never share your login credentials with anyone, log out after each session on shared devices, enable two-factor authentication, and immediately report any suspicious account activity to our support team at [email protected].

Breach Notification: In the unlikely event of a data breach that poses a risk to your rights and freedoms, hoki22 will notify you and relevant regulatory authorities in accordance with applicable data protection laws, typically within 72 hours of becoming aware of the breach.

6. Data Retention

hoki22 retains your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements:

• Active Accounts: For as long as your account remains active and in good standing, we retain your full personal profile, transaction history, and betting records to provide ongoing service.
• Closed Accounts: After you close your account, we retain certain data for a minimum period as required by gambling regulations and AML laws (typically 5-7 years) including identity verification documents, financial transactions, and account activity logs for audit and regulatory compliance purposes.
• Inactive Accounts: If your account remains inactive (no login or betting activity) for 12 consecutive months, we may archive or delete non-essential data while retaining records required by law. After 24 months of inactivity, we may close your account and apply our closed-account retention policy.
• Marketing Data: If you opt out of marketing communications, we suppress your contact information immediately and retain a record of your opt-out preference indefinitely to honor your choice.
• Dispute Records: If you have an open dispute or unresolved complaint, we retain all relevant data until the matter is resolved, even after account closure.

Once the retention period expires and data is no longer needed for legal or business purposes, we securely delete or anonymize your personal information using industry-standard data destruction methods (secure overwriting, degaussing, physical destruction of storage media).

7. Your Privacy Rights

Depending on your jurisdiction, you may have certain rights regarding your personal information. hoki22 respects these rights and provides mechanisms for you to exercise them:

• Right of Access: You can request a copy of the personal data we hold about you. We will provide this information in a commonly used electronic format within 30 days of your verified request.
• Right to Rectification: If any of your personal information is inaccurate or incomplete, you can request corrections. You can update most account information directly in your profile settings; for other changes, contact customer support.
• Right to Erasure (Right to be Forgotten): You can request deletion of your personal data in certain circumstances, such as when data is no longer necessary for its original purpose, you withdraw consent (where processing is based on consent), or you object to processing based on legitimate interest. Note that we may be legally required to retain some data even after a deletion request (such as transaction records for AML compliance).
• Right to Restriction of Processing: You can ask us to limit how we use your data in certain situations, such as when you contest the accuracy of data or object to processing based on legitimate interest.
• Right to Data Portability: Where technically feasible and legally required, you can request that we transfer your data to another service provider in a structured, commonly used, machine-readable format.
• Right to Object: You can object to processing of your data based on legitimate interest or for direct marketing purposes. For marketing, use the unsubscribe link in communications or adjust your account preferences.
• Right to Withdraw Consent: Where processing is based on consent, you can withdraw that consent at any time. This does not affect the lawfulness of processing that occurred before withdrawal.
• Right to Lodge a Complaint: If you believe hoki22 has not handled your data properly, you have the right to lodge a complaint with your local data protection authority or supervisory body.

Exercising Your Rights: To exercise any of these rights, please contact us at [email protected] with the subject line "Privacy Rights Request" and provide sufficient information to verify your identity. We will respond to verified requests within 30 days (or the timeframe required by applicable law). Some requests may require additional identity verification for security purposes.

8. Cookies & Tracking Technologies

hoki22 uses cookies, web beacons, pixels, local storage, and similar tracking technologies to enhance your browsing experience, analyze site usage, and deliver personalized content:

8.1 What Are Cookies?

Cookies are small text files placed on your device by your web browser when you visit a website. They allow the website to recognize your device on subsequent visits and store information about your preferences and activity.

8.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the website to function. These cookies enable core features like account login, security, session management, and load balancing. You cannot opt out of these cookies without severely impacting site functionality.
• Performance and Analytics Cookies: Help us understand how visitors interact with hoki22 by collecting anonymous information about pages visited, time spent, errors encountered, and traffic sources. We use this data to improve site performance and user experience. These cookies do not collect personally identifiable information.
• Functionality Cookies: Remember your preferences and choices (such as language, currency display, favorite games) to provide a more personalized experience. These enhance convenience but are not essential to basic site operation.
• Targeting and Advertising Cookies: May be used to deliver personalized advertisements on hoki22 or third-party sites based on your interests and browsing behavior. These cookies track your activity across websites to build a profile of your interests.

8.3 Managing Cookies

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies or alert you when a cookie is being sent. Please note that disabling cookies may limit your ability to use certain features of hoki22. To learn more about managing cookies in your specific browser, consult your browser's help documentation.

For more information about online advertising cookies and opting out, visit the Digital Advertising Alliance (DAA) at http://www.aboutads.info or the Network Advertising Initiative (NAI) at http://www.networkadvertising.org/choices/.

9. International Data Transfers

hoki22 operates internationally and may transfer, store, or process your personal data in countries outside Indonesia. These countries may have data protection laws that differ from Indonesian law. When we transfer data internationally, we implement appropriate safeguards including:

• Transferring data only to countries with adequate data protection frameworks;
• Using Standard Contractual Clauses (SCCs) approved by relevant data protection authorities;
• Ensuring our service providers implement equivalent technical and organizational security measures;
• Conducting due diligence on the legal environment of destination countries to ensure your data remains protected.

If you have concerns about international data transfers or would like more information about the safeguards we employ, please contact us using the details in Section 12.

10. Children's Privacy

hoki22 is an adults-only platform. We do not knowingly collect personal information from individuals under 21 years of age (or the minimum legal gambling age in your jurisdiction, whichever is higher). All users must confirm they meet minimum age requirements during registration. We employ age verification measures as part of our KYC process.

If we discover that we have inadvertently collected personal data from a minor, we will immediately delete that information and close the associated account. If you believe we have collected information from a minor, please contact us immediately at [email protected].

Parents and guardians are encouraged to monitor their children's internet use and employ parental control software to prevent minors from accessing gambling websites. For more information on protecting children online, visit our Responsible Gaming page.

11. Policy Updates

hoki22 may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or business operations. When we make significant changes, we will:

• Update the "Last Updated" date at the top of this policy;
• Notify you via email or prominent notice on the hoki22 website at least 30 days before the changes take effect;
• Where required by law, obtain your consent for material changes that expand how we use your personal data.

We encourage you to review this Privacy Policy periodically. Your continued use of hoki22 services after changes become effective constitutes acceptance of the updated policy. If you do not agree with any changes, you should close your account before the effective date.

Previous versions of this Privacy Policy are archived and available upon request for your reference.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy, data protection practices, or your personal information held by hoki22, please contact us through any of the following channels:

• Email: [email protected] (for privacy-specific inquiries, use subject line "Privacy Inquiry")
• Live Chat: Available 24/7 on the hoki22 website (select "Privacy & Data Protection" from the topic menu)
• Customer Support: 24/7 assistance in Indonesian and English
• Operating Hours: Available 24 hours daily in WIB (Western Indonesia Time, UTC+7)

For privacy rights requests (access, deletion, correction, etc.), please provide sufficient detail and identity verification to allow us to process your request efficiently. We will respond to verified requests within 30 days as required by applicable law.

For other hoki22 information and policies, please visit:

• About Us - Learn about hoki22's mission and values
• Terms & Conditions - Complete terms of service
• Responsible Gaming - Player protection tools and resources
• FAQ - Frequently asked questions