Privacy Policy

1. Introduction

5unsur ("the Platform", "we", "us", "our") operates the online gaming website accessible at https://5unsur.cam. In the course of providing our services — including sports betting, live casino games, slot games, and related account management functions — we necessarily process certain personal data belonging to our registered users ("you", "the User").

This Privacy Policy describes, in plain and precise language, the categories of personal data we collect, the lawful bases on which we process that data, the parties with whom we may share it, how long we retain it, and the rights available to you as a data subject. This Policy applies to all services offered through the 5unsur Platform, including the web interface, mobile-optimised site, and any associated customer support channels.

We are committed to handling your personal data responsibly and in accordance with internationally recognised data protection standards. Our practices draw on the principles established under major data protection frameworks, including those applicable to international gaming operators serving Indonesian residents. If you have questions about any aspect of this Policy, please refer to Section 15 for our contact details.

2. Definitions

• "Account" — the personal user account registered on the 5unsur Platform.
• "Controller" — the entity that determines the purposes and means of processing personal data. For this Policy, 5unsur is the Controller.
• "Cookie" — a small text file placed on your device by the Platform to store session or preference information.
• "Data Subject" — any identified or identifiable natural person whose personal data is processed by 5unsur; in the context of this Policy, this means you, the registered User.
• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, email address, phone number, IP address, financial information, and identity documents.
• "Processing" — any operation performed on personal data, including collection, recording, storage, use, disclosure, or deletion.
• "Processor" — a third party that processes personal data on behalf of 5unsur under a binding data processing agreement.
• "Special Category Data" — personal data revealing racial or ethnic origin, religious beliefs, health data, biometric data, or similar sensitive categories. 5unsur does not intentionally collect Special Category Data.

3. Data We Collect

We collect and process the following categories of personal data in connection with the operation of the 5unsur Platform:

4. How We Collect Your Data

5unsur collects personal data through the following means:

4.1 Direct Collection

You provide data directly when you complete the Account registration form, submit identity and address documents for KYC verification, initiate a deposit or withdrawal transaction, contact our customer support team via live chat, email, or WhatsApp, update your Account preferences, or respond to surveys or promotions.

4.2 Automated Collection

Technical and usage data is collected automatically when you access the Platform, including via cookies, web beacons, pixel tags, and server log files. This data is collected regardless of whether you are logged into your Account. See Section 9 for a full description of our cookie practices.

4.3 Third-Party Sources

We may receive data about you from third-party sources in limited circumstances, including: identity verification service providers who validate documents submitted during KYC; fraud-detection and anti-money-laundering screening databases; payment processors who confirm the status of transactions made via BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, Bank Permata, or any supported e-wallet service; and analytics providers who aggregate anonymised usage data.

5. Purpose and Legal Basis for Processing

We process your personal data only where we have a lawful basis for doing so. The table below maps each processing purpose to its applicable legal basis:

6. Data Sharing and Disclosure

5unsur does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share personal data only in the following strictly defined circumstances:

6.1 Service Providers and Processors

We engage carefully selected third-party service providers who process data on our behalf under binding data processing agreements. These include: identity verification and KYC platform providers; payment gateway operators facilitating transactions with Indonesian banks and e-wallets; game software providers (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, Pocket Games Soft, and others) who require session data to deliver games; cloud hosting and content delivery infrastructure providers; fraud detection and risk management platforms; and customer support software providers.

All Processors are contractually required to process personal data only for the specific purpose for which it is shared, to implement appropriate technical and organisational security measures, and to delete or return data upon the termination of the service relationship.

6.2 Legal and Regulatory Disclosure

We may disclose personal data to regulatory bodies, law enforcement agencies, courts, or other government authorities where required by applicable law, court order, or binding regulatory directive. Where legally permissible, we will notify you of such a disclosure request before complying.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of 5unsur's assets, personal data held by the Platform may be transferred to the acquiring entity as part of that transaction. You will be notified by email and through a prominent notice on the Platform at least 30 days before any such transfer takes effect, and you will retain the right to request deletion of your data prior to the transfer.

6.4 Aggregated and Anonymised Data

We may share aggregated, anonymised, or pseudonymised data — from which individual users cannot reasonably be identified — with business partners, analytics providers, or in published research. This sharing does not constitute a disclosure of personal data under applicable data protection standards and does not require your consent.

7. International Data Transfers

5unsur operates as an internationally licensed platform, and some of our third-party service providers are located in jurisdictions outside Indonesia. Where your personal data is transferred to a country that does not provide an equivalent level of data protection, we implement appropriate safeguards to ensure your data remains protected to the standard described in this Policy.

These safeguards include: contractual clauses that bind the recipient to data protection obligations consistent with internationally recognised standards; technical measures such as end-to-end encryption during transit; and strict access controls limiting who within a recipient organisation can view your data.

By registering an Account and using the 5unsur Platform, you acknowledge that your personal data may be processed in countries outside Indonesia as part of the delivery of our services. If you wish to obtain further information about the specific safeguards in place for any particular transfer, please contact our Data Protection Officer as described in Section 15.

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law, whichever is longer. The following retention periods apply as a general guide:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Where deletion is not immediately technically feasible, the data is isolated from active processing systems and scheduled for deletion in the next available purge cycle.

9. Cookies and Tracking Technologies

The 5unsur Platform uses cookies and similar tracking technologies to operate core site functionality, improve performance, and deliver a personalised experience. Below is a description of the cookie categories we use:

9.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function and cannot be disabled. They include session authentication tokens that keep you logged in, CSRF protection tokens that prevent cross-site request forgery attacks, load-balancing cookies that route your requests to the correct server, and cookies that store your responsible gaming preferences and session limits. No consent is required for strictly necessary cookies.

9.2 Performance and Analytics Cookies

These cookies collect anonymised information about how visitors use the Platform — which pages are visited most frequently, how long users spend on each section, and where users navigate from. This data is aggregated and used solely to improve the Platform's structure and content. These cookies are set by our analytics provider and do not identify you personally.

9.3 Functional Cookies

Functional cookies remember choices you make to improve your experience, such as your preferred language setting, the last game category you visited, and notification preferences. These cookies persist across sessions but do not track activity outside the 5unsur Platform.

9.4 Marketing and Retargeting Cookies

With your explicit consent, we may use cookies to deliver promotional content relevant to your interests and to measure the effectiveness of our marketing campaigns. You may withdraw consent for marketing cookies at any time by updating your browser cookie settings or contacting our support team. Withdrawal of marketing cookie consent does not affect the operation of strictly necessary or functional cookies.

9.5 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can typically configure your browser to block all cookies, accept only first-party cookies, or alert you when a cookie is being set. Please note that disabling strictly necessary cookies will impair core Platform functionality, including your ability to log in and maintain a gaming session. For instructions on managing cookies in your specific browser, please refer to your browser's help documentation.

10. Data Security

5unsur implements a comprehensive suite of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the 5unsur Platform is encrypted using industry-standard Transport Layer Security. The padlock icon in your browser confirms an active secure connection.
• Encryption at Rest: Personal data stored in our databases — including identity documents, financial records, and contact information — is encrypted at rest using AES-256 encryption.
• Access Controls: Personal data is accessible only to 5unsur personnel who have a documented, role-specific need to access it. Access privileges are reviewed quarterly and revoked immediately upon role change or departure.
• Two-Factor Authentication (2FA): All internal systems containing personal data are protected by mandatory two-factor authentication for staff access.
• Penetration Testing: The Platform undergoes regular third-party penetration testing and vulnerability assessments. Critical vulnerabilities are remediated within 24 hours of identification.
• Incident Response: 5unsur maintains a documented data breach response plan. In the event of a breach likely to result in risk to data subjects, affected users will be notified without undue delay.
• Staff Training: All staff with access to personal data receive mandatory data protection training upon joining and annually thereafter.

11. Your Data Subject Rights

As a data subject, you have a number of rights with respect to the personal data that 5unsur holds about you. These rights are described below. To exercise any of these rights, please submit a written request to our Data Protection Officer using the contact details in Section 15. We will respond to all verified requests within 30 days.

Please note that certain rights are subject to limitations where legal obligations require retention of the data in question, such as KYC records subject to anti-money-laundering retention requirements. Where a right cannot be exercised in full, we will explain the specific limitation in our response to your request.

12. Minors' Privacy

The 5unsur Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect, store, or process personal data relating to persons under the age of 21. All registration submissions are subject to age verification during KYC review, and any Account found to belong to a person under 21 will be closed immediately, with real-money deposits returned to the originating payment method.

If you are a parent or guardian and believe your child has registered an Account or provided personal data to 5unsur without your knowledge, please contact us immediately at [email protected]. We will investigate and, if confirmed, delete all personal data associated with the underage registration within 72 hours.

13. Third-Party Services and Links

The 5unsur Platform may contain references to or integrations with third-party services, including game software providers, payment processors, and analytics platforms. When you interact with a third-party service — for example, when a live casino game is loaded from a provider's servers — that third party may collect technical data about your session independently of 5unsur, subject to their own privacy policy.

5unsur is not responsible for the privacy practices of third-party service providers acting as independent data controllers. We encourage you to review the privacy policies of any third-party service you interact with. Our selection of service providers is guided by their demonstrated commitment to data security and privacy, and all providers used by 5unsur are subject to a vendor due-diligence review before engagement.

14. Amendments to This Policy

5unsur reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable legal requirements, or the services we offer. When we make material changes — for example, introducing a new category of data collection or a new sharing arrangement — we will notify all registered users by email at least 14 days before the changes take effect, and we will display a prominent notice on the Platform.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. We recommend reviewing this Policy periodically. Your continued use of the Platform after the effective date of a revised Policy constitutes your acknowledgement of the updated terms. If you do not agree with a material change, you have the right to close your Account and request deletion of your personal data before the change takes effect.

15. Contact and Data Protection Officer

5unsur has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and applicable data protection obligations. If you have any questions, concerns, or requests relating to your personal data or this Policy, please contact us through any of the following channels:

• Data Protection Officer Email: [email protected] — please include "Privacy Request" in the subject line for priority routing.
• Live Chat: Available 24/7 on the Platform. For data subject rights requests, ask to be connected to the compliance team.
• Response Time: We acknowledge all privacy requests within 48 hours and provide a substantive response within 30 calendar days. Complex requests may require up to 90 days; we will notify you if an extension is necessary.

All privacy-related communications are handled in strict confidence. Support agents are fluent in both Indonesian and English, ensuring that players across Jakarta, Surabaya, Medan, Bandung, Bali, and all other regions of Indonesia can communicate their concerns clearly and comfortably.

Our Privacy Commitments at a Glance

The following six commitments define how 5unsur approaches data protection across every aspect of its operations.